TN Lethal Injection Protocol Investigation Report and Findings 12-13-22

• Dec. 13, 2022 • Locations: United States of America -> Tennessee • Topics: Lethal Injection, Lethal Injection Method of Execution

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TENNESSEE LETHAL INJECTION
PROTOCOL INVESTIGATION
REPORT AND FINDINGS
Confidential Attorney-Client Communication
And Attorney Work Product

DECEMBER 13, 2022

Butler Snow LLP

BU T L E R I SNOW

INVESTIGATIVE REPORT
Confidential Attorney-Client Communication
And Attorney Work Product

To:

Governor Bill Lee

From:

Butler Snow LLP

Date:

December 13, 2022

Subject:

Tennessee Lethal Injection Protocol Investigation – Report
and Findings

BU T L E R I S

Preamble
On or about May 2, 2022, Governor Bill Lee (“Governor Lee”) announced plans to conduct
a third-party review into the circumstances that led him to issue a reprieve in connection with the
April 21, 2022, scheduled execution of Oscar Franklin Smith (“Mr. Smith”). Subsequently, Butler
Snow LLP (“Butler Snow”), led by Edward L. Stanton III, was retained to conduct an independent
investigation.1 Specifically, Governor Lee asked Butler Snow to conduct an independent review
of the following:


Circumstances that led to testing the lethal injection chemicals for only
potency and sterility but not endotoxins [in connection with] preparing for
the April 21 execution;



Clarity of the lethal injection process manual that was last updated in
2018, and adherence to testing policies since the update; and



TDOC staffing considerations.2

This report contains an analysis of Butler Snow’s review into the foregoing areas outlined
by Governor Lee. While some interviewees expressed opinions regarding the propriety of the
death penalty or necessity of endotoxin testing in future protocols, Butler Snow was not asked to
examine these issues and did not do so.

Throughout Butler Snow’s investigation, the State of Tennessee has demonstrated an
unwavering commitment to transparency and accuracy. The Tennessee Department of Correction
(“TDOC”) and the Office of the Tennessee Attorney General (the “Tennessee Attorney General’s
Office”) consistently provided the investigative team with the information/documents they sought
and gave them prompt access to all relevant employees requested to be interviewed in connection
with the instant investigation.

In addition to Edward L. Stanton III, the investigative team included S. Keenan Carter, Jennifer Svilar, and Alexa
Ortiz Hadley.
2

See Exhibit 1, Governor Lee’s May 2, 2022 Press Release.

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TABLE OF CONTENTS
Preamble ......................................................................................................................................... ii
Index of Documents .........................................................................................................................v
Executive Summary .........................................................................................................................1
A. Circumstances that led to testing the lethal injection chemicals for only potency and
sterility but not endotoxins [in connection with] preparing for the April 21 execution
........................................................................................................................................1
B. Clarity of the lethal injection process manual that was last updated in 2018, and
adherence to testing policies since the update ...............................................................1
C. TDOC staffing considerations .......................................................................................2
I.

Methodology and Scope of Independent Investigation ......................................................3

II.

Relevant Facts and Background...........................................................................................3
A. Events Triggering Independent Investigation ................................................................4
B. Adoption of Tennessee’s Lethal Injection Protocol.......................................................4
1. One-Drug Protocol and the Search for Pentobarbital ..............................................5
2. First Iteration of Three-Drug Protocol (January 2018) ...........................................7
3. Revisions Ahead of July 2018 Protocol .................................................................11
4. July 2018 Protocol and Extra-Protocol Instructions ..............................................13
C. Execution Training.......................................................................................................14

III.

Investigative Analysis ........................................................................................................16
A. Circumstances Surrounding the Scheduled Execution of Oscar Franklin Smith ........16
1. Day of Execution: TDOC ......................................................................................18
2. Day of Execution: Attorney General’s Office .......................................................19
3. Days Following Cancelled Execution ....................................................................20
B. Adherence to Protocol’s Testing Policies Since Update in July 2018 .........................21
1. Billy Ray Irick........................................................................................................23
2. Edmund Zagorski ...................................................................................................25
3. David Earl Miller ...................................................................................................26
4. Donnie Edward Johnson ........................................................................................27
5. Stephen West .........................................................................................................28
6. Lee Hall ..................................................................................................................31
7. Nicholas Sutton ......................................................................................................32
C. Clarity of and Adherence to the July 2018 Protocol ....................................................33
1. Inconsistencies in the Protocol...............................................................................33
2. Following the Protocol ...........................................................................................34
3. No Checks and Balances ........................................................................................36
D. TDOC Staffing Considerations ....................................................................................37
iii

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IV.

Investigative Findings and Recommendations ..................................................................38
A. Investigative Findings ..................................................................................................39
B. Recommendations ........................................................................................................40

Appendix A – Additional Documents Provided/Received ............................................................42

BU T L E R I S

Index of Documents

EXHIBITS
1

Governor Lee’s May 2, 2022, Press Release

Text Messages between Drug Procurer and Former Pharmacy Owner – fn 6, 9, 10

Emails between Drug Procurer and potential suppliers – fn 6

Letter from Alvogen, Inc.

Letter from Hikma Pharmaceuticals USA Inc.

Letters from Sandoz, Inc.

Emails between Drug Procurer and Pharmacy Owner dated May 15, 2019

Emails between Drug Procurer and Pharmacy Owner dated July 20, 2017

Emails between Drug Procurer and Pharmacy Owner dated October 30, 2019

Handwritten Notes of Drug Procurer dated February 25, 2020

Deposition Transcript of Debbie Inglis

Emails between Drug Procurer and Pharmacy Owner dated September 7, 2017

Emails between Drug Procurer and Pharmacy Owner dated September 21, 2017

Emails between Drug Procurer and Pharmacy Owner dated October 18, 2017

Emails between Drug Procurer and Pharmacy Owner dated October 26, 2017

Edited Excerpt of Protocol

Emails between Drug Procurer and Pharmacy Owner dated November 28, 2017
through December 4, 2017

LIC Inventory Page dated December 30, 2017

Edited LIC Protocol

LIC Protocol, July 2018

Pharmacy Services Agreement, June 25, 2015

Email from Pharmacy Owner to Drug Procurer dated July 16, 2018

Directions for Unpacking and Storage

Text Message between Drug Procurer and Pharmacy Owner dated July 5, 2018

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25

Emails between Pharmacy Owner and Pharmacist dated August 7, 2018

Text Messages between Drug Procurer and Pharmacy Owner dated August 7, 2018

Order, Smith v. State of Tennessee

Notice-Order-Stay of Execution (Death) Granted, Smith v. State of Tennessee

Notice-Order (other)-Misc. (Sua Sponte), Smith v. State of Tennessee

Smith Notification Letter, dated March 21, 2022

Smith Prescription, dated March 16, 2022

Testing Reports, dated March 21, 31, and April 8, 20, 2022

Email from K. Henry to D. Inglis, dated April 20, 2022

Email from K. Henry to D. Inglis, dated Aril 21, 2022

Email from K. Henry to D. Inglis, dated April 21, 2022

Text Messages between Drug Procurer and Pharmacist, dated April 20-21, 2022

Text Messages between Drug Procurer and Executioner, dated April 21, 2022

Drug Procurer Text Messages, dated April 20-22, 2022

Inventory of Items Preserved from April 21, 2022, Execution Prep

Emails between Gov. Lee’s office and TDOC, dated April 21-24, 2022

Test Reports

Text Messages between Drug Procurer and Pharmacy Owner dated August 8, 2019

Irick Prescription, dated July 18, 2018

Email from Pharmacy Owner to Drug Procurer, dated August 8, 2018

Testing Report, dated August 6, 2018

Email from Pharmacy Owner to Drug Procurer, dated August 6, 2018

Text Messages between Drug Procurer and Pharmacy Owner, dated July 25-26, 2018

Text Messages between Drug Procurer and Pharmacy Owner

Text Messages between Drug Procurer and Pharmacy Owner, dated August 7, 2018

Zagorski Notification Letter, dated September 27, 2018

Zagorski Prescription, dated September 21, 2018

Testing Reports, dated September 24 and October 8, 2018

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53

Text Messages between Drug Procurer and Pharmacy Owner, dated September 25,
2018

Testing Reports, dated September 24 and October 8, 2018

Email from Pharmacy Owner to Drug Procurer, dated October 10, 2018

Letter from D. Inglis to K. Henry re: State of Tennessee v. Zagorski

Zagorski Reprieve, dated October 11, 2018

Second Zagorski Prescription

Testing Report, dated November 7, 2018

Miller Notification Letter, dated November 21, 2018

Miller Prescription, dated November 16, 2018

Testing Reports, dated December 4, 5, 2018

Miller Notification Letter, dated November 23, 2018

Testing Reports

Johnson Notification Letter, dated April 16, 2019

Johnson Prescription, dated April 17, 2019

Testing Reports, dated April 26 and May 9, 2019

Email from Pharmacy Owner to Drug Procurer, dated April 29, 2019

Text Messages between Pharmacy Owner and Drug Procurer, dated May 8, 2019

Text Messages between Pharmacy Owner and Drug Procurer, dated May 9, 2019

Email from Pharmacy Owner to Drug Procurer, dated May 9, 2019

Email from K. Henry to D. Inglis, dated May 20, 2019

West Notification Letter

Text Messages between Drug Procurer and Pharmacy Owner, dated June 17, 21 and
24, 2019

Emails between Drug Procurer and Pharmacy Owner, dated June 26, 2019

Emails between Drug Procurer, Pharmacy Owner and Pharmacist, dated June 26 and
July 2, 2019

West Prescription, dated July 12, 2019

vii

BU TLE R I SNOW
79

Testing Reports, dated July 17, 30, 2019

Email from Pharmacy Owner to Drug Procurer, dated July 24, 2019

Text Messages between Pharmacy Owner and Drug Procurer, dated July 29-31, 2019

Email from Pharmacy Owner to Drug Procurer, dated July 31, 2019

Text Messages between Pharmacy and Drug Procurer, dated August 1, 2019

Testing Reports, dated August 7, 12, 2019

Testing Reports, dated July 31, 2019

Text Messages between Drug Procurer and Pharmacy Owner, dated August 8, 2019

Text Messages between Drug Procurer and Pharmacy Owner

Text Messages between Drug Procurer and Pharmacy Owner, dated August 8, 2019

Emails between Drug Procurer and Pharmacy Owner, dated August 8, 2019

Email from Pharmacy Owner to Drug Procurer, dated August 9, 2019

Text Messages between Drug Procurer and Pharmacy Owner, dated August 8-12,
2019

Emails from Pharmacy Owner to Drug Procurer, dated August 12, 2019

Hall Notification Letter, dated November 5, 2019

Hall Prescription, dated November 1, 2019

Testing Reports, dated November 18, 2019

Email from Pharmacy Owner to Drug Procurer, dated November 20, 2019

Testing Reports, dated November 22, 2019

Text Messages between Drug Procurer and Pharmacy Owner, dated November 25,
2019

Email from Pharmacy Owner to Drug Procurer, dated November 26, 2019

100

Text Messages between Drug Procurer and Pharmacy Owner, dated November 25 and
December 2, 2019

101

Testing Reports, dated December 5, 16, 2019

102

Text messages between Drug Procurer and Pharmacy Owner, dated December 3, 2019

103

Testing Reports, dated November 22, December 5, 16, 2019

104

Email from Pharmacy Owner to Drug Procurer, dated December 5, 2019

viii

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105

Testing Reports, dated December 5, 16, 2019

106

Sutton Prescription, dated December 19, 2019

107

Text Messages between Drug Procurer and Pharmacy Owner, dated December 25,
2019 and Jan. 2, 2020

108

Testing Reports, dated January 17, 27, 28, 2020

109

Testing Reports, dated January 17, 28, 2020

110

Sutton Affidavit Concerning Method of Execution

111

Testing Reports, dated January 17, 27, 28, 2020

112

Deposition Transcripts of Warden Tony Mays

ADDITIONAL DOCUMENTS PROVIDED/REVIEWED
See Appendix.

BU T L E R I SNOW

WITNESS INTERVIEW LIST
Tennessee Attorney General’s Office
1

Herbert Slatery — Former Attorney General

Andrée Blumstein — Solicitor General

Rob Mitchell — Senior Assistant Attorney General

Scott Sutherland — Deputy Attorney General

Dianna Shew — Chief Deputy Attorney General
Tennessee Department of Corrections

Lisa Helton — Interim Commissioner

Debbie Inglis — Deputy Commissioner/General Counsel

Tony Mays — Riverbend Maximum Security Institution Warden

Kelly Young — Inspector General

Executioner

Drug Procurer

Richard Muckle — Special Assistant to the Commissioner

Tony Parker — Former Commissioner
Pharmacy

Former Pharmacy Owner

Pharmacist

Current Pharmacy Owner
Reprieve Organization

Maya Foa — Joint Executive Director

Blaire Andres — Head of death penalty projects (United States)

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Federal Community Defender Office for the Eastern District of Pennsylvania
19

Alex Kursman —Assistant Federal Defender (Capital Habeas Corpus Unit)

Hayden Nelson-Major — Research/Writing Attorney (Capital Habeas Corpus Unit)
Federal Public Defender for the Middle District of Tennessee

Kelley Henry — Supervisory Assistant Federal Public Defender

Ben Leonard — Investigator
Bass, Berry & Sims PLC

David Esquivel

Jeremy Gunn

Sarah Miller
Brooklyn Law School

Alexis J. Hoag-Fordjour – Assistant Professor & Co-Director of the Center for
Criminal Justice

BU T L E R I S

EXECUTIVE SUMMARY
As independent investigators, Butler Snow conducted an impartial and comprehensive
review of all relevant evidence concerning the three areas referenced in Governor Lee’s May 2,
2022, press release.

This report addresses all relevant policies/protocols, describes related

investigative findings, and recommends specific steps to remedy and/or mitigate the likelihood of
any issues recurring in the future. The investigative findings are premised on the following:
witness interviews; in-depth historical research; an extensive and thorough review of thousands of
pages of relevant documents; and an analysis of lethal injection chemical testing data.

Based on the evidence obtained in the investigation, Butler Snow made the following
findings:

A. Circumstances that led to testing the lethal injection chemicals for only potency and
sterility but not endotoxins [in connection with] preparing for the April 21 execution


There is no evidence that any failure to test the lethal injection chemicals for endotoxins in
connection with Mr. Smith’s scheduled execution on April 21 was intentional.



There is no evidence that, when the State of Tennessee revised its lethal injection protocol
in 2018, it ever provided the pharmacy tasked with testing Tennessee’s lethal injection
chemicals with a copy of Tennessee’s lethal injection protocol.



There is no evidence that, when the State of Tennessee revised its lethal injection protocol
in 2018, any employee ever informed the pharmacy tasked with testing Tennessee’s lethal
injection chemicals that it should conduct an endotoxin test on all lethal injection chemicals
– until the eve of Mr. Smith’s scheduled execution on April 21.



The evidence shows that the pharmacy tasked with testing Tennessee’s lethal injection
chemicals only tested these chemicals for potency and sterility, because the pharmacy
followed the United States Pharmacopeia testing guidelines, not Tennessee’s lethal
injection protocol (which was never provided).

B. Clarity of the lethal injection process manual that was last updated in 2018, and
adherence to testing policies since the update


The evidence shows that the lethal injection chemicals used in the August 9, 2018,
execution of Mr. Billy Ray Irick (“Mr. Irick”) were not tested for endotoxins. The evidence

BU TLE R I SNOW
further shows that the Midazolam used during Mr. Irick’s execution was not tested for
potency.


The evidence shows that, although Edmund Zagorski (“Mr. Zagorski”) was executed via
electrocution on November 1, 2018, the lethal injection chemicals prepared in the event
Mr. Zagorski changed his mind and opted to be executed by lethal injection were not tested
in accordance with Tennessee’s lethal injection protocol. The lethal injection chemicals
were not tested for endotoxins and failed the potency testing.



The evidence shows that, although David Earl Miller (“Mr. Miller”) was executed via
electrocution on December 6, 2018, the lethal injection chemicals prepared in the event
Mr. Miller changed his mind and opted to be executed by lethal injection were not tested
in accordance with Tennessee’s lethal injection protocol. The lethal injection chemicals
were not tested for endotoxins.



The evidence shows that the lethal injection chemicals used in the May 16, 2019, execution
of Mr. Donnie Edward Johnson (“Mr. Johnson”) were not tested for endotoxins.



The evidence shows that, although Stephen West (“Mr. West”) was executed via
electrocution on August 15, 2019, the lethal injection chemicals prepared in the event Mr.
West changed his mind and opted to be executed by lethal injection were not tested in
accordance with Tennessee’s lethal injection protocol. The lethal injection chemicals were
not tested for endotoxins.



The evidence shows that, although Lee Hall (“Mr. Hall”) was executed via electrocution
on December 5, 2019, the lethal injection chemicals prepared in the event Mr. Hall changed
his mind and opted to be executed by lethal injection were not tested in accordance with
Tennessee’s lethal injection protocol. The lethal injection chemicals were not tested for
endotoxins.



The evidence shows that, although Nicholas Sutton (“Mr. Sutton”) was executed via
electrocution on February 20, 2020, the lethal injection chemicals prepared in the event
Mr. Sutton changed his mind and opted to be executed by lethal injection were not tested
in accordance with Tennessee’s lethal injection protocol. The lethal injection chemicals
were not tested for endotoxins.

C. TDOC staffing considerations


The evidence shows that TDOC leadership placed an inordinate amount of responsibility
on the Drug Procurer without providing much, if any, professional guidance; resources; or
assistance. Instead, TDOC leadership viewed the lethal injection process through a tunnelvision, result-oriented lens rather than provide TDOC with the necessary guidance and
counsel needed to ensure that Tennessee’s lethal injection protocol was thorough,
consistent, and followed.

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I.

METHODOLOGY AND SCOPE OF INDEPENDENT INVESTIGATION
Butler Snow’s review of the issues referenced in Governor Lee’s May 2, 2022, press

release involved the following steps:
(1)

Coordinating with the Tennessee Attorney General’s Office to obtain relevant
documents and interviewing various attorneys with pertinent information.

(2)

Coordinating with TDOC to obtain relevant documents and interviewing various
members of the department with pertinent information.

(3)

Coordinating with the Pharmacy used to supply Tennessee’s lethal injection
chemicals to obtain relevant documents and interviewing Pharmacy personnel with
relevant knowledge.

(4)

Collecting, organizing, reviewing, and analyzing relevant documents and data
obtained from the Tennessee Attorney General’s Office, TDOC, and the Pharmacy.

(5)

Conducting in excess of 25 interviews including, but not limited to, members of the
Tennessee Attorney General’s Office, TDOC, and the Pharmacy.

This report is organized in the following sections:

II.



Section II provides background history and information relating to the events that
triggered the instant investigation, the adoption of Tennessee’s lethal injection
protocol, and TDOC’s execution training.



Section III provides an analysis of the three investigative areas: (1) circumstances
surrounding the scheduled execution of Mr. Smith, (2) clarity of and adherence to the
lethal injection protocol’s testing policy since it was finalized in July 2018, and (3)
TDOC staffing considerations.



Section IV provides a summary of investigative findings and recommendations to
address/correct the Tennessee lethal injection protocol shortcomings discussed herein.

RELEVANT FACTS AND BACKGROUND
This Section provides an overview of the facts surrounding Governor Lee’s granting of a

temporary reprieve to Mr. Smith.3 Additionally, this Section provides information on Tennessee’s
efforts to revise its Lethal Injection Protocols (hereinafter, the “Protocol”) and to conduct

At age 40, Mr. Smith was convicted of murder in the October 1, 1989, killings of his estranged wife, Judy Robird
Smith and her minor sons, Chad Burnett and Jason Burnett.

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execution training at TDOC. This Section is intended for background purposes, and additional
facts and analysis will follow in the subsequent portions of this Report.
A. Events Triggering Independent Investigation
On April 21, 2022, Mr. Smith was scheduled to be executed by lethal injection. The day
before the execution, Mr. Smith’s attorneys contacted TDOC’s Deputy Commissioner of
Administration

and

General

Counsel,

Debbie

Inglis

(“Ms.

Inglis”

“Deputy

Commissioner/General Counsel”), to confirm whether the lethal injection chemicals (“LIC”) that
would be used during Mr. Smith’s execution had been properly tested in accordance with TDOC’s
LIC Protocol. TDOC determined that the LIC had not been tested for endotoxins4 as required by
Tennessee’s Lethal Injection Protocol (as revised, July 2018) (“July 2018 Protocol” or “current
Protocol”). As a result, Governor Lee issued a temporary reprieve to Mr. Smith on April 21, and
on May 2, Governor Lee called for an independent investigation, to be led by Edward L. Stanton,
III of Butler Snow. Governor Lee outlined three areas of review:
1. Circumstances that led to testing the LIC for only potency and sterility but not
endotoxins preparing for the April 21 execution;
2. Clarity of the lethal injection process manual (the Protocol) that was last updated
in 2018, and adherence to testing policies since the update; and
3. TDOC staffing considerations.

B. Adoption of Tennessee’s Lethal Injection Protocol
Over the years, the Protocol has been revised multiple times. These revisions include, but
are not limited to, title changes, drug changes, format changes, testing requirements, and the
addition of consciousness checks. This Section covers the changes pertaining to the LIC used for
executions.

Bacterial endotoxin testing measures the presence and quantity of endotoxins in a particular sample. The “endo”
in endotoxins refers to something that is within. The “toxin” component relates to something poisonous. Endotoxins
come from the cell walls of gram-negative bacteria.

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1. One-Drug Protocol and the Search for Pentobarbital

The Drug Procurer is responsible for obtaining the LIC that will be used in an execution
by lethal injection.5 This position is not defined in any iteration of the Protocol, nor are the
responsibilities of the role discussed in the Protocol. Based on instructions from former TDOC
Commissioner Tony Parker (“Commissioner Parker”),6 TDOC’s Deputy Commissioner/General
Counsel selected the current Drug Procurer in the summer of 2016. The same individual has served
as Drug Procurer for all LIC executions following the enactment of the current Protocol in July
2018. The current Drug Procurer described it as an “off the books” role, as procuring LIC is not
their7 sole responsibility with TDOC.8
Prior to the Drug Procurer assuming this role, TDOC carried out executions through a onedrug Protocol using a lethal dose of Pentobarbital. In creating this Protocol, TDOC consulted
experts who recommended the one-drug Protocol. Accordingly, the Drug Procurer was specifically
instructed, by Commissioner Parker, to locate a new source for Pentobarbital, because the
compounding pharmacist TDOC previously used could no longer obtain it.
Because TDOC did not have any policies in place for procuring LIC,9 the Drug Procurer
began conducting Google searches and making cold calls to active pharmaceutical ingredient
(“API”) suppliers located in the United States. They were provided with no direction, just the
directive to find a Pentobarbital source. In making calls, the Drug Procurer struggled to find a
source to supply Pentobarbital, as pharmacies/manufacturers did not have the chemical; did not

Although the Drug Procurer is an essential role, its position and corresponding duties are noticeably absent
from the current Protocol.
6

Commissioner Parker retired from his position as TDOC Commissioner effective on or about November
30, 2021.
7

With limited exceptions, this Report uses the pronoun “they” for all individuals referred to herein to
preserve anonymity.
8

Drug Procurement is neither the job title nor primary role of any TDOC employee.

Another individual served in this role prior to the current appointee, but that individual is no longer
employed with TDOC. The two did not exchange information about the responsibilities of the role.
5

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have the quantity requested by TDOC;10 or did not want to be associated with lethal injection
executions.11 TDOC determined that other states were also facing difficulty when trying to locate
a source for Pentobarbital. The Drug Procurer contacted at least one state to get information
regarding locating a source for Pentobarbital, but that state did not provide any beneficial
information.
In late 2016 to early 2017, the Drug Procurer cold-called a compounding pharmacy that
was willing to help look for Pentobarbital and agreed to compound the drug if found. This is the
same compounding pharmacy that currently supplies TDOC with compounded LIC based on the
Pharmacy Services Agreement entered into with TDOC in 2017 (hereinafter, the “Pharmacy”).12
The Drug Procurer’s primary point of contact was the Pharmacy’s owner.13 Before getting
involved with TDOC, the Pharmacy’s owners and Pharmacist met to ensure that all individuals
were willing to provide LIC (once found) to TDOC for use in executions. None of the individuals
voiced any concern or indicated that the Pharmacy should not work with TDOC. As a result, the
Pharmacy and Pharmacist undertook efforts to become licensed in Tennessee.
Efforts to find Pentobarbital continued even while the Pharmacy was awaiting licensure in
Tennessee. The Pharmacy Owner reached out to various suppliers,14 but Pentobarbital was either
only available in a small quantity, for limited purchasing only, or not available. The Pharmacy
Owner found a potential source, but that source would have required the Pharmacy to sign an
acknowledgment indicating the chemical would not be used for executions. As a result, the

Text messages between Drug Procurer and Pharmacy Owner, attached hereto as Exhibit 2 at 2-3; Emails
between Drug Procurer and potential suppliers, dated Apr. 4, 6, 2017 and June 20, 2018, attached hereto as
Exhibit 3.
11

See, e.g., Letter from Alvogen, Inc., dated Apr. 20, 2018, attached hereto as Exhibit 4; Letter from Hikma
Pharmaceuticals USA Inc., dated Feb. 26, 2020, attached hereto as Exhibit 5; Letters from Sandoz, Inc.,
dated Aug. 15, 2019 and Aug. 2, 2018, attached hereto as Exhibit 6.
12

Pharmacy Services Agreement, attached hereto as Exhibit 21.

The Pharmacy Owner left the Pharmacy in early 2020, and from that point forward, the Drug Procurer
communicated with the Pharmacist directly.
14

Text messages between Drug Procurer and Pharmacy Owner, attached hereto as Exhibit 2 at 3 (listing
the following suppliers: Cardinal Health, McKesson, Medisca, PCCA, ANDA, Amerisource Bergen, Sigma
Aldrich).
6

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Pharmacy could not use the source. The Pharmacy Owner and Drug Procurer also considered the
possibility of obtaining Pentobarbital from a veterinarian because “[t]hey sometimes have better
access to it since it’s widely used for euthanasia in animals.”15 That effort never came to fruition.
It became clear to TDOC that it was extremely difficult finding a U.S.-based source that
would provide Pentobarbital in the amount needed for use in lethal injection executions. The Drug
Procurer and Pharmacy Owner also investigated whether the drug could be obtained from an
international source and imported.16 It was ultimately determined that the United States Drug
Enforcement Administration (“DEA”) would not allow Pentobarbital to be imported because it is
a schedule II drug that was considered “readily available” in the United States.17
Even if considered “readily available” by the DEA, TDOC was unable to obtain
Pentobarbital. Because Pentobarbital was unavailable, TDOC made the decision to adopt a threedrug Protocol. The Drug Procurer’s efforts to locate Pentobarbital continued into at least 2020,18
even after TDOC adopted its new three-drug Protocol and removed the Pentobarbital Protocol
(identified as Protocol A) from TDOC’s current Protocol. Even today, TDOC officials prefer a
one-drug protocol to the three-drug protocol.19 With a one-drug protocol, TDOC representatives
told investigators there is a lower risk of mistake in carrying out an execution. Further, according
to at least one TDOC official, the potential for mistakes also increases when more compounded
LIC are used.
2. First Iteration of Three-Drug Protocol (January 2018)

Having been unable to obtain Pentobarbital for its then one-drug Protocol, in the Fall of
2017, TDOC began inquiring about developing a new three-drug Protocol. Commissioner Parker

Text messages between Drug Procurer and Pharmacy Owner, dated Apr. 6, 2017, attached hereto as
Exhibit 2 at 1.
16

Emails between Drug Procurer and Pharmacy Owner, dated May 15, 2019, attached hereto as Exhibit 7;
Emails between Drug Procurer and Pharmacy Owner, dated July 20, 2017, attached hereto as Exhibit 8.
17

Emails between Drug Procurer and Pharmacy Owner, dated Oct. 30, 2019, attached hereto as Exhibit 9.

Handwritten Notes of Drug Procurer, dated Feb. 25, 2020, attached hereto as Exhibit 10.

Dep. Tr. of Debbie Inglis at 37-39, attached hereto as Exhibit 11.
7

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did some research on his own but relied on his Deputy Commissioner/General Counsel, the Drug
Procurer, and the Tennessee Attorney General’s Office to establish the new, three-drug Protocol.
Commissioner Parker reviewed the written Protocol but did not have any involvement in drafting
it, including the portions that address testing of LIC, which he assumed were drafted in
consultation with the Pharmacist.20

In early September of 2017, the Drug Procurer informed the Pharmacy Owner that TDOC
wanted “to try to find Midazolam and then go from there” if Midazolam was unavailable.21 The
Pharmacy Owner responded that both Midazolam and Potassium Chloride were “readily available”
and that they had “reviewed several protocols from states” with three-drug protocols that use those
drugs along with a paralytic.22 The Pharmacy Owner voiced “concern with Midazolam,” stating
that “[b]eing a benzodiazepine, it does not elicit strong analgesic effects,” meaning “[t]he subjects
may be able to feel pain from the administration of the second and third drugs.” The Drug Procurer
agreed to “pass this info on to the higher ups.”23

Nevertheless, TDOC chose to proceed with a three-drug Protocol that included Midazolam,
Vecuronium Bromide, and Potassium Chloride. The Drug Procurer notified the Pharmacy Owner
of this decision on September 21, 2017 and asked various questions about the dosage for each,
available quantity, cost, shelf life and storage conditions.24 In response, the Pharmacy Owner
explained that the Vecuronium Bromide was available in a powder which would require
reconstituting, noted the “typical dosing” for Potassium Chloride, and advised on the quantity
required for both.25 The Pharmacy Owner further explained that “there would be no need to

Commissioner Parker never spoke to the Pharmacist, as he was advised against such contact by TDOC’s
attorneys.
21

Emails between Drug Procurer and Pharmacy Owner, dated Sept. 7, 2017, attached hereto as Exhibit 12.
(RE: Update)
22

Id.

Emails between Drug Procurer and Pharmacy Owner, dated Sept. 21, 2017, attached hereto as Exhibit
13.
25

Id.

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compound” at that point and that the commercially available drugs could be maintained at room
temperature and would have a shelf life of one to two years.26 The Drug Procurer communicated
this information back to their TDOC superiors.
The Pharmacy began obtaining commercially-manufactured LIC in October 2017.
According to the Pharmacy Owner, by October 18, 2017, the Pharmacy had received Midazolam
that would expire in June 2018, Vecuronium Bromide that would expire in December 2018, and
Potassium Chloride that would expire in May 2018.27 On October 26, 2017, the Drug Procurer
again asked the Pharmacy Owner for information on how the LIC needed to be stored as well as
how to prepare them for injection.28 The Pharmacy Owner replied that the LIC should be “stored
in a secured location at room temperature (between 15 and 30 degrees [Celsius]),” and that they
would instruct the Pharmacist to draft a protocol on how to prepare them.29 The Pharmacy Owner
also attached a proposed Pharmacy Services Agreement, which contained terms related to the
Pharmacy’s provision of prescription medication and compounded preparations. The Pharmacy
Owner and Drug Procurer discussed and made various changes to the terms of this Agreement, but
the Pharmacy requirements related to compounding (including compliance with pharmaceutical
standards, the United States Pharmacopoeia guidelines and accreditation departments) remained
the same.
Around that same time, the Drug Procurer and Pharmacy Owner exchanged a draft of
certain pages of the Protocol in development. In particular, the Drug Procurer provided the
Pharmacy Owner with copies of six pages of the Protocol, including full sections entitled
“Chemicals Used in Lethal Injection” and “Protocol B: Lethal Injection Chemical Set-Up and
Preparation,” as well as one page of the section ultimately entitled “Chemical Administration and
IV Monitoring.”30 The Pharmacy Owner made one revision to these pages, changing the size of

Id.

Emails between Drug Procurer and Pharmacy Owner, dated Oct. 18, 2017, attached hereto as Exhibit
14.
28

Emails between Drug Procurer and Pharmacy Owner, dated Oct. 26, 2017, attached hereto as Exhibit
15.

Id.

Edited Excerpt of Protocol, attached hereto as Exhibit 16.
9

BU T LE R

IS ow

the syringe used for administration of Potassium Chloride to reduce the number of syringes used
in an execution from three to two. The Pharmacy Owner sent these revisions to the Drug Procurer
on November 28, 2017, along with a signed copy of the finalized Pharmacy Services Agreement.31
As of December 2017, the Protocol had not yet been updated. In preparation for the
transition to the new three-drug Protocol, by the end of 2017, TDOC had acquired a bulk order of
commercially manufactured Midazolam, Vecuronium Bromide, and Potassium Chloride from the
Pharmacy. This order kickstarted the first revision of the Protocol to add the three-drug protocol.
The January 2018 version of the Protocol included both protocol alternatives using commerciallymanufactured drugs: (A) lethal injection by Pentobarbital and (B) lethal injection by Midazolam,
Vecuronium Bromide, and Potassium Chloride.

CHE ICAL- U ED IN LETHAL I JECTION
The Departme nt will use one of he following protocols

a 6 · etenninecl

by he

ommissioner:

fro tocoJ A:
Peutoba r hi taJ

Midazolam

Vecuro ium

100 ml of a 50 mglmL sol ution (a total of 5 g a ms)

00 ml of a 5rn g/ml ·olutjon {a total of 500 mg)
100 m1 of s l mg/ml sol ution (a total of 100 mg)

Bt'omide

Potassium

120 ml. oh. 2 mEq/m.l solu tion (a total of 240 mEq)

Chloride

Protocol A was kept because TDOC’s search for Pentobarbital was ongoing. Because the
January 2018 Protocol does not provide for the use of compounded LIC, there is no discussion of
testing in this version of the Protocol.

Emails between Drug Procurer and Pharmacy Owner, dated Nov. 28, 2017 through Dec. 4, 2017, attached
hereto as Exhibit 17.
10

BU T L E R I S

3. Revisions Ahead of July 2018 Protocol
Executions resumed under Tennessee’s current Protocol in mid-2018, beginning with the
execution of Billy Ray Irick (“Mr. Irick”) on August 9, 2018. By this point, TDOC had Potassium
Chloride and Vecuronium Bromide that would not expire until July 2019 and June 2020,
respectively; however, the Midazolam it had previously acquired was scheduled to expire in June
2018, meaning TDOC would need to procure additional Midazolam for executions.32

By the time TDOC began efforts to acquire additional Midazolam in 2018, the Pharmacy
was no longer able to obtain it in a commercially manufactured form due to suppliers requesting
assurances that the drug would not be used for executions. As a result, TDOC began ordering
Midazolam in its API form to be compounded by the Pharmacy. Based upon information conveyed
to investigators, compounded drugs—in contrast to their commercially manufactured
counterparts—should undergo certain testing under pharmaceutical guidelines, have different
storage and preparation requirements, and have a much shorter shelf life.
In July 2018, TDOC, in coordination with the Tennessee’s Attorney General’s Office,
revised the initial three-drug Lethal Injection Protocol to include reference to these additional
requirements where the LIC are compounded. TDOC also removed alternative “A” – the
Pentobarbital protocol – given TDOC’s continued inability to obtain it.33

LIC Inventory Page, dated Dec. 30, 2017, attached hereto as Exhibit 18.

Edited Protocol, attached hereto as Exhibit 19.
11

BU T L E R j S

CHEMICALS USED IN LETH AL INJEC TION
ns by lethal
The Departm ent will use the following protocol for carrying out executio
injection:

Midazo lam

100 ml of a 5mg/ml solution (a total of 500 mg)

Vecuro11iu1n
Bromid e

100 ml of a lmg/ml solution (a total of 100 mg)

Potassi um
Chlorid e

120 ml of a 2 mE q/ml solu tion (a toLal of240 mEq)

roveu
Chemica ls used in lethal injection executions will either be FDA-app
in
prepared
ions
preparat
ded
compoun
be
shall
or,
drugs;
tured
commer cially manufac
States
United
the
with
nt
compliance with pharmaceutical standard s consiste
ce with applicable
Pharmac opeia guidelines. and accredH ation Departm ents, and in accordan
ns.
licensing regulatio

According to the Drug Procurer, they consulted the Pharmacy Owner in the course of
TDOC’s revision of the Protocol, particularly with respect to testing and storage requirements and
compliance with the United States Pharmacopoeia (“USP”) guidelines. The Drug Procurer told
investigators that, the Pharmacy Owner recommended testing for sterility,34 potency35 and
endotoxins for compounded LIC. Interestingly, both the Pharmacy Owner and Drug Procurer
expressed the belief to investigators that sterility testing included endotoxin testing,36 but
according to the Pharmacist, there are separate tests for sterility and endotoxins. Further, the
Pharmacist noted that USP Chapter 797 only requires testing for endotoxins when compounding
more than 25 doses at a time. When compounding single-dose vials—as the Pharmacist does for
TDOC—the Pharmacist understands that USP Chapter 797 does not require endotoxin testing and

Sterility testing is used to confirm sterile products do not contain viable microorganisms before release
and patient administration.
35

Potency testing measures the concentration of the API. It is necessary to ensure the quality, safety, and
efficiency of biopharmaceutical products.
36

The Pharmacy Owner, like the Drug Procurer, is not a pharmacist and has had no pharmaceutical training.
The Pharmacy Owner’s medical training consists of on-the-job training as an orthopedic scrub technician.
12

BU T L E R I S

only requires “skip lot” testing (i.e. testing approximately every other batch) for sterility and
potency. Regardless, there is no dispute that TDOC’s current Protocol requires endotoxin testing.

4. July 2018 Protocol and Extra-Protocol Instructions
The resulting, revised Protocol requires a physician’s order for compounded drugs and
requires the Pharmacist to compound the drugs “in a clean sterile environment in compliance with
pharmaceutical standards for identity, strength, quality, and purity of the compounded drug that
are consistent with the United States Pharmacopoeia guidelines and accreditation Departments and
in accordance with applicable licensing regulations pertaining to pharmacies compounding sterile
preparations.”37 The current Protocol then references the Pharmacy Services Agreement, which
contains nearly identical language.38 The current Protocol further requires the Pharmacist to
arrange for independent testing of compounded drugs for potency, sterility and endotoxins.39
Finally, it defers to the Pharmacy’s directions, pharmaceutical standards, and the USP guidelines
with respect to the transfer, storage and maintenance of compounded LIC,40 as well as Pharmacy
directions for preparing the syringes for use in an execution.41
Specific directions related to the preparation of syringes for compounded LIC were not
included in the current Protocol itself. Instead, the Pharmacy provided the Drug Procurer with
separate preparation instructions for Midazolam—the only compounded LIC in use at the time—
in July 2018.42 Similarly, because compounded drugs must be transported and stored at below-

July 2018 Protocol, attached hereto as Exhibit 20 at 35.

Id.

Id. The testing requirements also appeared in a 2015 version of a Pharmacy Services Agreement that
TDOC may have had with its previous compounding pharmacy. See Agreement, dated June 25, 2015,
attached hereto as Exhibit 21. This language does not appear in the current Agreement between TDOC
and the Pharmacy.
40

July 2018 Protocol, Exhibit 20 at 35.

Id. at 39.

Email from Pharmacy Owner to Drug Procurer, dated July 16, 2018, including Revised IV Protocol,
attached hereto as collective Exhibit 22.
13

BU T L E R I S

freezing temperatures, the Pharmacy also provided Directions for Unpacking and Storage43 with
each shipment of compounded LIC, which were packed with dry ice. The Midazolam Preparation
Instructions require transfer of the compounded Midazolam from the freezer to the refrigerator 24
hours prior to use and explain how to prepare the syringe, which includes adding both Midazolam
and saline solution to the syringe.44 Neither the current Protocol nor these instructions explain
how far in advance of an execution compounded LIC should be removed from the refrigerator and
prepared in a syringe.45
In advance of Mr. Irick’s scheduled execution, on or about August 7, 2018,46 the Pharmacy
Owner and Pharmacist participated in a phone call with the Executioner and at least one
intravenous (“IV”) Team Member for the purpose of (1) explaining how to prepare the Midazolam,
(2) explaining how to reconstitute the Vecuronium Bromide, and (3) answering questions from the
Execution Team.

C. Execution Training
In order to carry out safe and effective executions, Riverbend Maximum Security
Institution (“RMSI”) conducts monthly practice drills.47 Under the Protocol, members of the
Execution Team simulate Day 3 (day of execution) of the death watch procedures for at least one
hour per month.48 The training may last longer if needed. Additional training is held within two

Directions for Unpacking and Storage, attached hereto as Exhibit 23.

Revised IV Protocol, Exhibit 22 at 2-4.

Drug Procurer asked Pharmacy Owner about this via text message on July 5, 2018, to which Pharmacy
Owner responded “My assumption is that it would need to be used within an hour. I’ll confirm with the
pharmacist.” Text Message between Drug Procurer and Pharmacy Owner, dated July 5, 2018, attached
hereto as Exhibit 24.
46

Emails between Pharmacy Owner and Pharmacist, dated Aug. 7, 2018, attached hereto as Exhibit 25;
Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 7, 2018, attached hereto as
Exhibit 26
47

As part of the investigation, Butler Snow’s investigative team attended one of the monthly training
sessions in person.
48

Protocol, Exhibit 20 at 32.
14

BU T L E R I S

weeks before a scheduled execution, at which point RMSI conducts rehearsals at least twice per
week.49
As lethal injection is the primary method of execution in Tennessee, the monthly training
focuses on the procedures for carrying out executions by lethal injection. Every quarter, RMSI
also practices its procedures for carrying out executions by electrocution. If an execution by
electrocution is scheduled, then the Execution Team will focus more on those procedures during
the monthly training sessions. The Warden oversees all such training, and the TDOC
Commissioner also attends many of the practices. All individuals who undergo the training are
required to sign training rosters, which are maintained by TDOC.
During the lethal injection training, all steps of an execution are practiced with the
following exceptions, as outlined in the Protocol:
A. [TDOC staff] volunteers play the roles of the condemned inmate and the physician.
B. Saline solution is substituted for the lethal chemicals.
C. A body is not placed in the body bag.50
Beyond monthly training, the Executioner receives initial and periodic instruction from a
qualified medical professional.51 For instance, the Executioner and other members of the IV Team
have received training on how to start an IV in case the emergency medical technicians (“EMTs”)
are not available. During training, the IV Team practices pushing three syringes of saline, and
because they cannot push the actual LIC, nor can they compound any LIC on hand, they simulate
the remaining syringes.

Protocol, Exhibit 20 at 32.

Protocol, Exhibit 20 at 32.
15

BU T L E R I S
III.

INVESTIGATIVE ANALYSIS

This section provides Butler Snow’s analysis of the facts learned through document review
and investigative interviews based on the three areas of investigation provided by Governor Lee.

A. Circumstances Surrounding the Scheduled Execution of Oscar Franklin Smith
Oscar Franklin Smith was originally scheduled to be executed on June 4, 2020.52 Mr. Smith
filed a motion to stay his execution due to the COVID-19 pandemic, and a stay was granted on
April 17, 2020.53 His execution was initially reset for February 4, 2021.54 The COVID-19 stay was
lifted, and Mr. Smith’s execution was reset for April 21, 2022.55 On March 21, 2022, TDOC
informed Mr. Smith that his execution would be carried out by lethal injection “according to the
protocol and procedures in TDOC’s Lethal Injection Manual, as amended on July 5, 2018, using
a three-drug combination consisting of Midazolam, Vecuronium Bromide, and Potassium
Chloride.”56
A physician’s prescription for Midazolam and Potassium Chloride was issued for Mr.
Smith on March 16, 2022.57 The Pharmacy compounded the Midazolam and Potassium Chloride
and sent samples to the independent testing laboratory58 (the “Lab”) for sterility and potency
testing on or about March 18 (Potassium Chloride) and April 6 (Midazolam) of 2022. The
Potassium Chloride sample passed sterility testing on March 21, and the Midazolam sample passed

Order, Smith v. State of Tennessee, Case No. M2016-01869-SC-R11-PD, attached hereto as Exhibit 27.

Notice – Order – Stay Execution (Death) Granted, Smith v. State of Tennessee, Case No. M2016-01869SC-R11-PD, attached hereto as Exhibit 28.
54

Id.

Notice – Order (Other) – Miscellaneous (Sua Sponte), Smith v. State of Tennessee, Case No. M201601869-SC-R11-PD, attached hereto as Exhibit 29.
56

Smith Notification Letter, dated Mar. 21, 2022, attached hereto as Exhibit 30.

Smith Prescription, dated Mar. 16, 2022, attached hereto as Exhibit 31.

The Pharmacy has used the same independent testing laboratory since it began working with TDOC.
16

BU T L E R I S

sterility testing on April 20.59 The Potassium Chloride sample yielded a within-range potency of
103% on March 31, and the Midazolam sample yielded a within-range potency of 102% on April
8. The Pharmacist subsequently provided the test results to the Drug Procurer.60 The samples were
not tested for endotoxins.
The LIC arrived at RMSI on or about April 12. On April 12, 14 and 18, lethal injection
training was conducted at the prison.61 On April 20, the LIC were moved to the refrigerator for
thawing prior to the execution. Also, on April 20, Mr. Smith’s attorney, Kelley Henry (“Ms.
Henry”), sent an email to TDOC’s Deputy Commissioner/General Counsel (1) inquiring about
whether the LIC to be used in Mr. Smith’s execution had been tested for “strength, sterility,
stability, potency, and presence of endotoxins” and (2) requesting a copy of the test results.62 The
Deputy Commissioner/General Counsel informed TDOC Interim Commissioner Lisa Helton
(“Interim Commissioner Helton”) about Ms. Henry’s request.
The Deputy Commissioner/General Counsel forwarded the email to the Drug Procurer63 to
determine the status of the LIC testing. The Drug Procurer, in turn, contacted the Pharmacist on
April 20 to determine if an endotoxin test had been conducted or if the endotoxin test was the same
as sterility testing.64 According to a text exchange between the Drug Procurer and the Pharmacist:
“No endotoxin test, it’s a different test but based on USP 797 the amount we make isn’t required.

Based on this date, the Pharmacist would have had to send the LIC to the Drug Procurer before the test
results came back because the execution was scheduled for the following day (April 21), and the LIC must
thaw for 24 hours before they can be used. Butler Snow did not find any evidence of when the LIC were
sent for Mr. Smith’s execution.
60

Testing Reports, dated Mar. 21, 31, and Apr. 8, 20, 2022, attached hereto as Exhibit 32.

See supra for a discussion of TDOC’s execution training protocols.

Email from K. Henry to D. Inglis, dated April 20, 2022, attached hereto as Exhibit 33. Ms. Henry also
sent a follow-up email on April 21, 2022, at 5:50:42 PM, again requesting the testing results. A copy of this
email is attached hereto as Exhibit 34. Later that same day, Ms. Henry sent an email asking TDOC to
preserve all records, documents, drugs, and drug paraphernalia that were to be used in Mr. Smith’s
execution. A copy of this email is attached hereto as Exhibit 35.
63

Other individuals with TDOC and the Tennessee Attorney General’s office received the email, either by
virtue of being cc’d or via forward.
64

Text messages between Drug Procurer and Pharmacist, dated Apr. 20-21, 2022, attached hereto as
Exhibit 36.
17

BU T L E R I S

Is the endotoxin test requested? Sorry I didn’t have it tested.”65 The Drug Procurer indicated a
belief that endotoxin testing had been done on prior occasions and that they would contact the
Pharmacist on the following day to discuss the USP 797 guidelines.66 Therefore, at least one TDOC
employee was aware that no endotoxin testing had been conducted on the LIC during the evening
of the day before Mr. Smith’s scheduled execution.
1. Day of Execution: TDOC
On the morning of April 21, 2022, the Drug Procurer asked the Pharmacist whether the
Lab still had samples and would be able to do the endotoxin testing that day.67 The Pharmacist
responded that the testing could not be done because they would have had to send extra samples
for the Lab to do endotoxin testing.68 Around lunchtime on April 21, TDOC employees who were
to be involved in the execution gathered at Interim Commissioner Helton’s residence for a final
walk-through – which is customary on the scheduled day of an execution. During this time, there
were also ongoing conversations between TDOC, the Tennessee Attorney General’s Office, and
Governor Lee’s office. TDOC advised that if the LIC were not tested for endotoxins, then TDOC
would need to ask Governor Lee for a reprieve. At that point, the Drug Procurer indicated that the
testing was not required by USP guidelines. Even so, it was required by the current Protocol, and
as such, TDOC would seek a reprieve because the Protocol was not followed. The Tennessee
Attorney General’s Office also recommended a reprieve.
During the afternoon of Mr. Smith’s execution day, while the reprieve request was still
being considered, the Execution Team needed to proceed as though the execution would go as
scheduled. For instance, Execution Team members needed to take their stations, and the victims’
family needed to be moved to their locations. Media representatives also were scheduled to be at
RMSI for the execution. For this reason, Interim Commissioner Helton chose to move forward and

Id.

Id. The Pharmacist also testified in a deposition to having tested for endotoxins before, but as explained
above, they only did endotoxin testing on the initial batch of Midazolam when they were testing the
methodology.
67

Id.

Id.
18

BU T L E R I SNOW
continue preparing for the execution until the reprieve was issued. Around 4:30 PM CT, the Drug
Procurer met the Executioner to get the LIC out of the refrigerator and transport the LIC to the
Execution Chamber.69 About 5:30 PM CT, the Execution Team began preparing the syringes to
be used during the execution.
TDOC learned that the reprieve would be issued at 5:45 PM CT. Interim Commissioner
Helton advised Warden Tony Mays, who told Mr. Smith about the reprieve. Mr. Smith’s attorney
and spiritual advisor were also present when the news was delivered. Interim Commissioner
Helton also spoke with members of TDOC to assure them that they had done a good job preparing
for the execution. Once the execution was called off, TDOC stopped setup of the LIC at
approximately 5:51 PM CT.70 The Execution Team had partially prepared the first (red) set of LIC
(saline and Vecuronium Bromide) but had not yet mixed the compounded LIC. TDOC then
undertook efforts to preserve the LIC and all documentation in the event of an investigation.71
2. Day of Execution: Tennessee’s Attorney General’s Office
Around 1:30 PM CT on April 21, 2022, members of the Tennessee Attorney General’s
Office met to review documents, review the Protocol, and discuss next steps. The Tennessee
Attorney General’s Office team concluded that they could not state that TDOC followed the
Protocol in preparing for Mr. Smith’s execution. Accordingly, the attorneys turned their focus to
how best to respond to Mr. Smith’s attorney’s inquiry. They also spoke with the Pharmacist, who
indicated that they had done endotoxin testing in the past but not for the LIC to be used in Mr.
Smith’s execution. At this point, the Pharmacist purportedly indicated that the lack of endotoxin
testing was an “oversight.”72 The group also spoke with the Drug Procurer, and one member of the
Tennessee Attorney General’s Office spoke with an expert, who was also a pharmacist and

Text messages between Drug Procurer and Executioner, dated Apr. 21, 2022, attached hereto as Exhibit
37.
70

Drug Procurer text messages, dated Apr. 20-22, 2022, attached hereto as Exhibit 38.

Inventory of Items Preserved from Apr. 21, 2022 Execution Prep, attached hereto as Exhibit 39.

The Pharmacist was clear when speaking to Butler Snow that only one endotoxin test had ever been
performed because it was not required under the USP guidelines based on the amount of drugs compounded.
The purpose of the one endotoxin test, performed in May 2018, was to test the Pharmacy’s compounding
methodology.
19

BU TLE R I SNOW
explained why endotoxin testing was important. After the reprieve was issued, members of the
Tennessee Attorney General’s Office were invited to the executive residence for a meeting with
Governor Lee regarding the execution events.
3. Days Following Cancelled Execution
After issuing the reprieve in connection with Mr. Smith’s execution, Governor Lee’s office
asked for a copy of the current Protocol and other documents that would aid in determining why
the LIC were not tested for endotoxins. TDOC compiled the requested documents and provided
them to Governor Lee’s office. At some point between April 21 and 27, the question was raised
regarding whether endotoxin testing had been conducted in connection with the lethal injection
executions TDOC conducted as scheduled subsequent to adopting the July 2018 Protocol. The
Pharmacist apparently had informed the Drug Procurer that they had not done endotoxin testing
for any of the prior executions because the test was not required under USP guidelines. The
Pharmacist indicated to Butler Snow that they were surprised when the Drug Procurer asked if
endotoxin testing had been performed for the LIC for Mr. Smith’s execution because they had
never been asked to do endotoxin testing before. The Pharmacist was also unaware that endotoxin
testing was part of the Protocol. In fact, Butler Snow has found no evidence that the current
Protocol was ever provided to the Pharmacy. It appears that the Pharmacist was following the USP
guidelines to determine what tests to conduct on the LIC, because TDOC never sent them the
Protocol. The Pharmacist had no way of knowing TDOC finalized and implemented the Protocol.
The Tennessee Attorney General’s Office requested documents, including all LIC testing records.
On April 22, 2022, the Tennessee Attorney General’s Office received 31 pages of testing results
dating back to 2018, although only 17 of those had been produced previously in litigation.
On April 24, in response to an inquiry from the Governor’s office, the Drug Procurer
provided the following information regarding TDOC’s policies for lethal injection: (1) the Protocol
does not require any additional testing of the LIC beyond the tests conducted by the Lab after the
Pharmacy compounds the LIC; (2) there is no policy or procedure in place to address how the LIC
test results are to be maintained following TDOC’s receipt; (3) there is no log book to track
periodic testing, since it is not required, but all third-party test results are received and maintained

BU T L E R I SNOW
by the Drug Procurer; and (4) there are no documents evidencing TDOC’s review (yearly or
otherwise) of the Protocol.73
By April 27, it became clear that none of the LIC used and/or prepared for post-2018
executions had been tested for endotoxins. Further, TDOC learned that there were additional
problems with the testing of the LIC used in Mr. Irick’s execution in 2018 because there was also
no potency testing completed.74 The explanation provided by the Pharmacy Owner at the time was
that the potency test conducted for the batch in May 2018 was good for the LIC provided for the
scheduled execution of Mr. Irick in August 2018. Through the course of their post Mr. Smith
reprieve dialogue with the Pharmacist, TDOC learned that this was in fact not true.
As stated earlier in this Report, there is no indication that TDOC provided the Pharmacy
with a copy of the July 2018 Protocol, under which all of the executions covered in this Report
were carried out. The Pharmacist did not conduct endotoxin testing unless it was requested, and
TDOC did not specifically request endotoxin testing results until the day of Mr. Smith’s execution.
However, TDOC consistently only requested sterility and potency testing results from the
Pharmacy in connection with each scheduled lethal injection execution.75

B. Adherence to Protocol’s Testing Policies Since Update in July 2018

Since the Protocol was updated in July 2018, there have been a total of seven executions,
two of which were by lethal injection, and five of which were by electrocution.76 Butler Snow’s
review of TDOC’s adherence to the Protocol necessitated a review of each execution carried out
by TDOC since adoption of the July 2018 Protocol. Butler Snow discovered that only one sample
of Midazolam was ever tested for endotoxins, and no samples of Potassium Chloride were tested

Emails between Gov. Lee’s office and TDOC, dated Apr. 21-24, 2022, attached hereto as Exhibit 40.

See infra for more information.

TDOC likely did not request endotoxin testing because the Drug Procurer was operating under the
mistaken belief that endotoxin testing was incorporated in the sterility testing.
76

Executions by electrocution are covered under TDOC’s Electrocution Protocol (updated March 13,
2017). These executions are only discussed here because, as explained above, TDOC decided to have LIC
available for all executions, regardless of the method chosen by the condemned.
21

BU T L E R I SNOW
for endotoxins. The only endotoxin test was conducted in May 2018, a few months before Mr.
Irick’s execution. The following is an illustration of the LIC testing results during the relevant
timeframe:

LIC Testing Results Spreadsheet
Test Date

Drug

Test

Results

5/22/2018

Midazolam

Pass

5/14/2018

Midazolam

Pass

5/10/2018

Irick

5/11/2018
5/11/2018
5/25/2018
8/6/2018
9/24/2018
10/8/2018
11/7/2018
12/4/2018
12/5/2018
4/26/2019
5/9/2019
7/17/2019
7/30/2019
7/18/2019
7/30/2019
7/31/2019
8/12/2019
8/7/2019
8/9/2019
11/18/2019
11/22/2019
12/5/2019
12/5/2019
12/16/2019
1/17/2020
1/28/2020
1/27/2020
1/28/2020
7/21/2020

Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Midazolam
Potassium Chloride
Potassium Chloride
Midazolam
Midazolam
Potassium Chloride
Potassium Chloride
Potassium Chloride
Potassium Chloride
Midazolam
Midazolam
Potassium Chloride
Midazolam
Potassium Chloride
Potassium Chloride
Potassium Chloride
Midazolam
Midazolam
Potassium Chloride

Suitability
Container Closure
Integrity
Potency
Bacterial Endotoxins
Sterility
Sterility
Potency
Sterility
Potency
Potency
Sterility
Potency
Sterility
Potency
Sterility
Potency
Sterility
Suitability
Potency
Potency
Sterility
Potency
Potency
Potency
Sterility
Sterility
Potency
Sterility
Potency
Sterility
Potency

Date
Received
5/10/2018

97.00%
Pass
Pass
Pass
94.20%
Pass
54.20%
89.40%
Pass
104.00%
Pass
112.00%
Pass
92.40%
Pass
Pass
94.00%
94.00%
Pass
114.00%
98.60%
94.70%
Pass
Pass
104.00%
Pass
100.00%
Pass
99.50%

5/10/2018
5/10/2018
5/10/2018
7/21/2018
9/22/2018
9/22/2018
10/27/2018
11/21/2018
11/21/2018
4/25/2019
4/25/2019
7/16/2019
7/16/2019
7/16/2019
7/16/2019
7/26/2019
8/6/2019
8/6/2019
8/6/2019
11/13/2019
11/21/2019
12/2/2019
11/21/2019
12/2/2019
1/14/2020
1/14/2020
1/14/2020
1/14/2020
7/17/2020

Irick
Irick
Irick
Irick
Zagorski
Zagorski
Zagorski
Miller
Miller
Johnson
Johnson
West
West
West
West
West
West
West
West
Hall
Hall
Hall
Hall
Hall
Sutton
Sutton
Sutton
Sutton
Nichols

Inmate
Irick

BU T L E R I SNOW
Test Date

Drug

Test

Results

7/21/2020
7/31/2020
7/31/2020
4/8/2022
4/20/2022
3/21/2022
3/31/2022

Midazolam
Midazolam
Potassium Chloride
Midazolam
Midazolam
Potassium Chloride
Potassium Chloride

Potency
Sterility
Sterility
Potency
Sterility
Sterility
Potency

98.40%
Pass
Pass
102.00%
Pass
Pass
103.00%

Date
Received
7/17/2020
7/17/2020
7/17/2020
4/6/2022
4/6/2022
3/18/2022
3/22/2022

Inmate
Nichols
Nichols
Nichols
Smith
Smith
Smith
Smith

1. Billy Ray Irick

In May 2018, the Pharmacy sent a sample of its first compounded batch of Midazolam to
the external Lab for testing. That sample was tested for method suitability,77 container closure
integrity,78 potency, bacterial endotoxins, and sterility.79 Although not all tests are required under
the USP, the Pharmacist explained that they requested these tests for their first compounded batch
to ensure their compounding process was sound. The sample passed each of the tests and yielded
a within-range potency of 97%. It appears that this lot was essentially a “test run,” given that this
was the first time the Pharmacy would be compounding Midazolam rather than ordering it in
commercially manufactured form. According to the Pharmacy Owner—in text messages80 with
the Drug Procurer—passing the method suitability test indicates that the Pharmacy’s method for
compounding the drug is sound and translates across multiple batches. However, passing results
on one batch for potency, sterility, and endotoxins does not necessarily indicate that a subsequent
batch will yield the same test results. Based on the 45-day shelf life of compounded Midazolam,
the batch tested in May 2018 would have surpassed its beyond-use date prior to Mr. Irick’s
execution date in August 2018.

Method suitability testing is performed to determine whether any inhibitory or antimicrobial properties
in a drug product will prevent the sterility test from detecting the presence of viable microorganisms.
78

Container closure integrity testing is performed to evaluate the adequacy of a closure in maintaining a
sterile barrier.
79

Testing Reports, attached hereto as Exhibit 41.

Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 8, 2019, attached hereto as
Exhibit 42.
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A physician’s prescription for Midazolam was issued for Mr. Irick on July 18, 2018,81 and
the Pharmacy compounded the Midazolam on July 20.82 A sample of that lot was sent for testing
on or about July 21, 2018.83 This lot was tested for sterility on August 6, 2018 and passed,84 and
the Pharmacy Owner sent those test results to the Drug Procurer via email the same day.85 Text
messages between the Drug Procurer and the Pharmacy Owner indicate that, at TDOC’s urging,
the Pharmacy Owner shipped the Midazolam to TDOC before receiving those test results.86

This lot of Midazolam was not tested for potency or endotoxins. When the sterility test
came back, the Drug Procurer asked the Pharmacy Owner via text message about the potency
results.87 The Pharmacy Owner replied that the pharmacist did not request a potency verification
given that our methodology and suitability passed in May with the same midazolam lot.88 The
Drug Procurer asked whether this indicated that “the potency portion is good for that whole 50gram batch.”89 The Pharmacy Owner responded:

“Our methodology is good for any batch of midazolam. It just verifies that how we
process the compound yields the intended dosing within an acceptable range.
Potency testing isn’t required for every lot, however, given the sensitive nature of

Irick Prescription, dated July 18, 2018, attached hereto as Exhibit 43.

Email from Pharmacy Owner to Drug Procurer, dated Aug. 8, 2018, including copy of Logged Formula
Worksheet, dated July 20, 2018, attached hereto as Exhibit 44.
83

Testing Report, dated Aug. 6, 2018, attached hereto as Exhibit 45.

Id. (25)

Email from Pharmacy Owner to Drug Procurer, dated Aug. 6, 2018, including copy of Testing Report,
dated Aug. 6, 2018, attached hereto as Exhibit 46.
86

Text messages between Drug Procurer and Pharmacy Owner, dated July 25-26, 2018, attached hereto as
Exhibit 47.
87

Text messages between Drug Procurer and Pharmacy Owner, attached hereto as Exhibit 48.

Id.

Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 7, 2018, attached hereto as
Exhibit 49.
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BU T L E R I S

its intended use, I have instructed [the Pharmacist] to request it every time moving
forward.”90

The Drug Procurer accepted this explanation and did not inform the Pharmacy Owner that
a potency test was nevertheless required under the Protocol. It appears that this batch of
Midazolam was used in the execution of Mr. Irick on August 9, 2018.

2. Edmund Zagorski

Edmund Zagorski (“Mr. Zagorski”) was initially scheduled to be executed on October 11,
2018 by lethal injection.91 A physician’s prescription for Midazolam was issued for Mr. Zagorski
on September 21, 2018.92 Upon compounding the Midazolam, the Pharmacy sent a sample of that
lot to the Lab for testing on or about September 22, which was tested for both sterility and
potency.93 While this testing was pending, the Drug Procurer asked the Pharmacy Owner “to go
ahead and ship the latest batch” on September 25, which the Pharmacy Owner did.94 The sample
ultimately passed the sterility test and yielded a within-range potency of 94.2%.95 The Pharmacy
Owner sent these results to the Drug Procurer via email on October 10, 2018.96 The sample was
not tested for endotoxins.

On October 8, Mr. Zagorski apparently submitted an Affidavit Concerning Method of
Execution purporting to waive his right to execution by lethal injection and electing to be executed

Id.

Zagorski Notification Letter, dated Sept. 27, 2018, attached hereto as Exhibit 50.

Zagorski Prescription, dated Sept. 21, 2018, attached hereto as Exhibit 51.

Testing Reports, dated Sept. 24 and Oct. 8, 2018, attached hereto as Exhibit 52.

Text messages between Drug Procurer and Pharmacy Owner, dated Sept. 25, 2018, attached hereto as
Exhibit 53.
95

Testing Reports, dated Sept. 24 and Oct. 8, 2018, attached hereto as Exhibit 54.

Email from Pharmacy Owner to Drug Procurer, dated Oct. 10, 2018, including Testing Report, attached
hereto as Exhibit 55.
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BU T L E R I S

by electrocution instead.97 Given this late change, then Tennessee Governor Bill Haslam issued a
reprieve on October 11, which remained in effect until October 21.98 Mr. Zagorski ultimately
confirmed his decision to be executed by electrocution, to which TDOC agreed, and his execution
was rescheduled for November 1. Nevertheless, although not explicitly required by the Protocol,
TDOC made the decision from that point forward to obtain LIC for each execution in the event of
a last-minute method change. Accordingly, a second physician’s prescription for Midazolam was
issued for Mr. Zagorski on October 24,99 the Pharmacy compounded the Midazolam, and sent a
sample to the Lab for sterility and potency testing on or about October 27.100 The sample was not
tested for endotoxins. By the time the potency test was completed on November 7—yielding a
below-range result of 54.2%—Mr. Zagorski had already been executed by electrocution on
November 1.

3. David Earl Miller

David Earl Miller (“Mr. Miller”) was scheduled to be executed on December 6, 2018, and
TDOC notified Mr. Miller by letter dated November 21 that it planned to carry out this execution
by lethal injection.101 A physician’s prescription for Midazolam was issued for Mr. Miller on
November 16,102 and the Pharmacy compounded the Midazolam and sent a sample to the Lab for
sterility and potency testing on or about November 21.103 Mr. Miller elected to be executed by
electrocution on November 23.104 The sample later passed sterility testing but yielded a below-

Letter from D. Inglis to K. Henry re: State of Tennessee v. Edmund Zagorski, M1996-00110-SC-DPEDD, dated Oct. 9, 2018, attached hereto as Exhibit 56.
98

Zagorski Reprieve, dated Oct. 11, 2018, attached hereto as Exhibit 57.

Second Zagorski Prescription, attached hereto as Exhibit 58.

100

Testing Report, dated Nov. 7, 2018, attached hereto as Exhibit 59.

101

Miller Notification Letter, dated Nov. 21, 2018, attached hereto as Exhibit 60.

102

Miller Prescription, dated Nov. 16, 2018, attached hereto as Exhibit 61.

103

Testing Reports, dated Dec. 4, 5, 2018, attached hereto as Exhibit 62.

104

Miller Notification Letter signed by Miller, dated Nov. 23, 2018, attached hereto as Exhibit 63.
26

BU T L E R I SNOW
range potency of 89.4%.105 The sample was not tested for endotoxins. The Midazolam was not
used, as Mr. Miller was executed by electrocution on December 6 as scheduled.

4. Donnie Edward Johnson

Donnie Edward Johnson (“Mr. Johnson”) was scheduled to be executed on May 16, 2019
by lethal injection.106 A physician’s prescription for Midazolam was issued for Mr. Johnson on
April 17, 2019,107 the Pharmacy compounded the Midazolam, and sent a sample to the Lab for
sterility and potency testing on or about April 25.108 The potency test came back first, on April
26, with a within-range result of 104%. The Pharmacy Owner sent this result to the Drug Procurer
on April 29.109 While the sterility test was still pending, the Drug Procurer asked the Pharmacy
Owner via text message if they could send the Midazolam to TDOC early, stating “[It would] be
good to go ahead and get it stored since next week will be execution week and a little hectic.”110
The Pharmacy Owner agreed and shipped the Midazolam on May 8 via priority overnight.111 The
package arrived and the sterility test came back the next day—May 9—with a passing result, which
the Pharmacy Owner sent to the Drug Procurer.112 The sample was not tested for endotoxins. Mr.
Johnson was executed by lethal injection on May 16 as scheduled with the compounded
Midazolam received from the Pharmacy and the unexpired, commercially-manufactured

105

Testing Reports, Exhibit 64.

106

Johnson Notification Letter, dated Apr. 16, 2019, attached hereto as Exhibit 65.

107

Johnson Prescription, dated Apr. 17, 2019, attached hereto as Exhibit 66.

108

Testing Reports, dated Apr. 26 and May 9, 2019, attached hereto as Exhibit 67.

109

Email from Pharmacy Owner to Drug Procurer, dated Apr. 29, 2019, including Testing Report, attached
hereto as Exhibit 68.
110

Text messages between Pharmacy Owner and Drug Procurer, dated May 8, 2019, attached hereto as
Exhibit 69.
111

Text messages between Pharmacy Owner and Drug Procurer, dated May 8, 2019, attached hereto as
Exhibit 70.
112

Text messages between Pharmacy Owner and Drug Procurer, dated May 9, 2019, attached hereto as
Exhibit 71; Email from Pharmacy Owner to Drug Procurer, dated May 9, 2019, including Testing Report,
attached hereto as Exhibit 72.
27

BU T L E R I S

Vecuronium Bromide and Potassium Chloride that TDOC still had in its inventory. Following Mr.
Johnson’s execution, on May 20, 2019, Ms. Henry requested “all data regarding the lethal injection
chemicals used in the execution including the results of the sterility testing of the chemicals[.]”113

5. Stephen West

Stephen West (“Mr. West”) was scheduled to be executed on August 15, 2019 by lethal
injection.114 Because the Potassium Chloride in TDOC’s inventory would expire in July 2019,
TDOC needed to acquire both Midazolam and Potassium Chloride in advance of Mr. West’s
planned execution. As with the Midazolam in early 2018, the Pharmacy was no longer able to
obtain commercially-manufactured Potassium Chloride, necessitating it to compound the drug
instead. In preparation for this switch, the Pharmacist drafted separate Preparation Instructions for
Potassium Chloride at the Drug Procurer’s request.115 The Pharmacy Owner and Drug Procurer
exchanged drafts of these instructions on June 26, 2019, with the Drug Procurer making edits to
the quantity of saline, number of syringes, and certain outlined steps.116 The Pharmacy Owner
forwarded the Drug Procurer’s revised draft to the Pharmacist, who approved the same on July
2.117 Like the Midazolam Preparation Instructions, these instructions require transfer of the
compounded Potassium Chloride from the freezer to the refrigerator 24 hours prior to use and
explain how to prepare the syringe, but they do not instruct on how far in advance of an execution
to prepare that syringe.

113

Email from K. Henry to D. Inglis, dated May 20, 2019, attached hereto as Exhibit 73.

114

West Notification Letter, attached hereto as Exhibit 74.

115

Text messages between Drug Procurer and Pharmacy Owner, dated June 17, 21 and 24, 2019, attached
hereto as Exhibit 75.
116

Emails between Drug Procurer and Pharmacy Owner, dated June 26, 2019, including Potassium Chloride
Preparation Instructions, attached hereto as Exhibit 76.
117

Emails between Drug Procurer, Pharmacy Owner and Pharmacist, dated June 26 and July 2, 2019,
attached hereto as Exhibit 77.
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BU T L E R I S

A physician’s prescription for Midazolam and Potassium Chloride was issued for Mr. West
on July 12, 2019.118 The Pharmacy compounded the Midazolam and Potassium Chloride and sent
samples to the Lab for sterility and potency testing on or about July 16.119

The Midazolam sample yielded a within-range potency of 92.4% on July 18, but the
Potassium Chloride sample yielded an above-range potency of 112% on July 17.120 The Pharmacy
Owner sent both results to the Drug Procurer on July 24.121 By separate text message, the
Pharmacy Owner instructed the Drug Procurer to “scratch that batch” of Potassium Chloride in
light of the above-range potency result and informed the Drug Procurer that the Pharmacy had
prepared and sent another batch for testing.122 The Midazolam sample passed sterility testing on
July 30, and the Pharmacy Owner sent those results to the Drug Procurer via email the next day.123

On August 1, the Pharmacy Owner informed the Drug Procurer via text message that the
Pharmacy was “having issues with the potassium chloride” and that they “can’t use it” because it
was “falling out of solution.”124 According to investigative interviews, when a drug is falling out
of solution, it means the API is not fully dissolving into the intended liquid form during the
compounding process.

The Pharmacy ultimately compounded several batches and sent a

successful sample of one of those batches to the Lab for sterility and potency testing on or about

118

West Prescription, dated July 12, 2019, attached hereto as Exhibit 78.

119

Testing Reports, dated July 17, 30, 2019, attached hereto as Exhibit 79.

120

Id.

121

Email from Pharmacy Owner to Drug Procurer, dated July 24, 2019, including Testing Reports, attached
hereto as Exhibit 80.
122

Text messages between Pharmacy Owner and Drug Procurer, dated July 29-31, 2019, attached hereto as
Exhibit 81.
123

Email from Pharmacy Owner to Drug Procurer, dated July 31, 2019, including Testing Report, attached
hereto as Exhibit 82.
124

Text messages between Pharmacy Owner and Drug Procurer, dated Aug. 1, 2019, attached hereto as
Exhibit 83.
29

BU T L E R I S

August 6, 2019.125 It appears a separate sample was also sent for Suitability testing and passed.126
On August 8, while this testing was pending, the Drug Procurer asked the Pharmacy Owner via
text message if they could send the LIC the following day, explaining “[the] higher ups [don’t]
wanna [sic] wait till [sic] Tuesday.”127 The Pharmacy Owner agreed. The Drug Procurer also
asked if they could rely on the sterility testing from a prior batch of Potassium Chloride for sterility
on the new batch.128 Initially, the Pharmacy Owner replied “Absolutely.” However, in response
to further questioning by the Drug Procurer regarding USP guidelines for relying on testing from
a prior batch, the Pharmacy Owner explained “You could rely on that as proof that our
methodology is valid. You cannot apply one lot’s sterility to another lot.”129

The Drug Procurer and Pharmacy Owner made further edits to the Pharmacy’s instructions
for Potassium Chloride on August 8.130 On August 9, the Pharmacy Owner also sent the Drug
Procurer an “in-house sterility report” for the Potassium Chloride batch, which showed a passing
result.131 The Drug Procurer continued to follow up with the Pharmacy Owner via text message
in the subsequent days regarding test results.132 On August 12, the Pharmacy Owner emailed the
potency test report for the Potassium Chloride, which showed a within-range potency of 94%.133

125

Testing Reports, dated Aug. 7, 12, 2019, attached hereto as Exhibit 84.

126

Testing Reports, dated July 31, 2019, attached hereto as Exhibit 85.

127

Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 8, 2019, attached hereto as
Exhibit 86.
128

Text messages between Drug Procurer and Pharmacy Owner, attached hereto as Exhibit 87.

129

Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 8, 2019, attached hereto as
Exhibit 88.
130

Emails between Drug Procurer and Pharmacy Owner, dated Aug. 8, 2019, including Potassium Chloride
Preparation Instructions, attached hereto as Exhibit 89.
131

Email from Pharmacy Owner to Drug Procurer, dated Aug. 9, 2019, including In-House Sterility Report,
dated Aug. 6, 2019, attached hereto as Exhibit 90. Note that the Protocol requires the Pharmacist to arrange
independent testing of the LIC. See Protocol, Exhibit 20 at 35.
132

Text messages between Drug Procurer and Pharmacy Owner, dated Aug. 8-12, 2019, attached hereto as
Exhibit 91.
133

Emails from Pharmacy Owner to Drug Procurer, dated Aug. 12, 2019, including Testing Reports dated
Aug. 7, 12, 2019, attached hereto as Exhibit 92.
30

BU T L E R I S

The sample was not tested for endotoxins. Ultimately, Mr. West elected to be executed by
electrocution, which proceeded as scheduled on August 15.

6. Lee Hall

Lee Hall (“Mr. Hall”) was scheduled to be executed on December 5, 2019 by lethal
injection.134 A physician’s prescription for Midazolam and Potassium Chloride was issued for Mr.
Hall on November 1, 2019.135 Shortly thereafter, Mr. Hall elected to be executed by electrocution;
however, consistent with its practice, TDOC proceeded to obtain back-up LIC. The Pharmacy
compounded a batch of Midazolam and sent a sample to the Lab for sterility and potency testing
on or about November 13.136 The potency test came back on November 18 with an above-range
potency of 114%. The Pharmacy Owner sent this result to the Drug Procurer via email on
November 20.137
The Pharmacy compounded a second batch of Midazolam and sent a sample to the Lab for
sterility and potency testing on or about November 21.138 The potency test on that sample came
back on November 22 with a within-range potency of 98.6%. On November 25, the Pharmacy
Owner shipped two packages to the Drug Procurer—presumably the Midazolam and Potassium
Chloride—and sent shipping information via text message.139 The Pharmacy Owner then sent the
Midazolam potency result to the Drug Procurer via email on November 26.140

134

Hall Notification Letter, dated Nov. 5, 2019, attached hereto as Exhibit 93.

135

Hall Prescription, dated Nov. 1, 2019, attached hereto as Exhibit 94.

136

Testing Reports, dated Nov. 18, 2019, attached hereto as Exhibit 95.

137

Email from Pharmacy Owner to Drug Procurer, dated Nov. 20, 2019, including Testing Report dated
Nov. 18, 2019, attached hereto as Exhibit 96.
138

Testing Report, dated Nov. 22, 2019, attached hereto as Exhibit 97.

139

Text messages between Drug Procurer and Pharmacy Owner, dated Nov. 25, 2019, attached hereto as
Exhibit 98.
140

Email from Pharmacy Owner to Drug Procurer, dated Nov. 26, 2019, attached hereto as Exhibit 99.
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BU T L E R I SNOW
At some point, the Pharmacy also compounded a batch of Potassium Chloride and sent it
to the Lab for sterility and potency testing; however, on December 2, the Pharmacy Owner texted
the Drug Procurer to inform him that they had “missed the mark by 2% points” on the Potassium
Chloride and were sending a new batch.141 The Pharmacy sent a sample of that new batch to the
Lab for potency and sterility testing on or about December 2.142 The Pharmacy Owner then mailed
the new Potassium Chloride to TDOC on December 3.143 On December 5, the second batch of
Midazolam passed sterility testing and the second batch of Potassium Chloride yielded a withinrange potency of 94.7%.144 The Pharmacy Owner sent both results to the Drug Procurer the same
day.145 Mr. Hall was executed via electrocution as scheduled that evening. The Pharmacy did not
receive a passing sterility result on the Potassium Chloride until December 16.146 None of the
samples were tested for endotoxins.

7. Nicholas Sutton

Nicholas Sutton (“Mr. Sutton”) was scheduled to be executed on February 20, 2020. A
physician’s prescription for Midazolam and Potassium Chloride was issued for Mr. Sutton on
December 19, 2019.147 Around that time, the Pharmacy Owner—TDOC’s only contact at the
Pharmacy—began transitioning out of the Pharmacy as a result of a buyout of their ownership
share, with their last day scheduled for January 15, 2020.148 The Drug Procurer and the New

141

Text messages between Drug Procurer and Pharmacy Owner, dated Nov. 25 and Dec. 2, 2019, attached
hereto as Exhibit 100.
142

Testing Reports, dated Dec. 5, 16, 2019, attached hereto as Exhibit 101.

143

Text messages between Drug Procurer and Pharmacy Owner, dated Dec. 3, 2019, attached hereto as
Exhibit 102.
144

Testing Reports, dated Nov. 22, Dec. 5, 16, 2019, attached hereto as Exhibit 103.

145

Email from Pharmacy Owner to Drug Procurer, dated Dec. 5, 2019, including Testing Reports dated
Nov. 22 and Dec. 5, 2019, attached hereto as Exhibit 104.
146

Testing Reports, dated Dec. 5, 16, 2019, attached hereto as Exhibit 105.

147

Sutton Prescription, dated Dec. 19, 2019, attached hereto as Exhibit 106.

148

Text messages between Drug Procurer and Pharmacy Owner, dated Dec. 25, 2019 and Jan. 2, 2020,
attached hereto as Exhibit 107.
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BU T L E R I S

Pharmacy Owner discussed TDOC’s desire to continue working with the Pharmacy. Thereafter,
the Drug Procurer began communicating directly with the Pharmacist, not the Pharmacy Owner.

The Pharmacy compounded the Midazolam and Potassium Chloride and sent samples to
the Lab for sterility and potency testing on or about January 14, 2020.149 The Potassium Chloride
yielded a within-range potency of 104% on January 17.150 On January 21, Mr. Sutton elected to
be executed by electrocution.151 The Midazolam ultimately yielded a within-range potency of
100% on January 27, and both the Midazolam and Potassium Chloride passed their sterility tests
on January 28.152 The samples were not tested for endotoxins. Butler Snow has not seen any record
to indicate that the Pharmacist sent these results to TDOC prior to Mr. Sutton’s execution. Mr.
Sutton was executed by electrocution as scheduled on February 20, 2020.
C. Clarity of and Adherence to the July 2018 Protocol
1. Inconsistencies in the Protocol
Many individuals interviewed by Butler Snow indicated that there are inconsistencies
contained with the July 2018 Protocol. The interviewees attributed any inconsistencies to revisions
being made to one section or an addition of a new section without reviewing the entire document
to determine if other areas have been impacted. Beyond the LIC testing failures that are the
primary focus of this investigation, gaps and inconsistencies have been noted, particularly by
TDOC employees, but changes have yet to be made. For instance, as noted above, one of the most
significant gaps is the absence of any reference to the Drug Procurer or their responsibilities in the
Protocol. It is Butler Snow’s understanding that although the term “Drug Procurer” came about
through litigation, the Drug Procurer responsibilities preexisted any litigation referencing the role.
The current Protocol does not have any discussion of steps to be taken by the Drug Procurer when

149

Testing Reports, dated Jan. 17, 27, 28, 2020, attached hereto as Exhibit 108.

150

Testing Reports, dated Jan. 17, 28, 2020, attached hereto as Exhibit 109.

151

Sutton Affidavit Concerning Method of Execution, attached hereto as Exhibit 110.

152

Testing Reports, dated Jan. 17, 27, 28, 2020, attached hereto as Exhibit 111.
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BU T L E R I S

acquiring LIC. Furthermore, there is no discussion of how the Drug Procurer (or any other
individual) should go about confirming that the required independent testing has been conducted.

Another issue with the current Protocol raised during the investigative interviews addressed
the storage and accountability of the compounded LIC. For example, the Protocol states that the
compounded LIC are to be stored in “an unmovable heavy gauge steel container with security
grade locks.”153 The Investigative Team observed that the LIC are stored securely but not in an
“unmovable heavy gauge steel container” as mandated. As a result, the Protocol should be revised
to reflect the true nature in which the LIC are stored. There are also no LIC temperature
requirements referenced in the Protocol, no LIC storage guidelines, or instructions regarding when
the LIC should be removed to allow for thawing. Accordingly, TDOC relies exclusively on the
instructions from the Pharmacy with regard to how the compounded LIC are to be stored.154

Finally, another unanswered question exists regarding how far in advance of an execution
a compounded LIC should be removed from the refrigerator and prepared in a syringe. Neither the
Protocol nor the Pharmacy’s instructions address this issue. The compounded LIC have a very
short shelf-life, and this information is seemingly essential to ensuring an execution is carried out
with only viable LIC.

2. Following the Protocol

Inconsistencies in the Protocol preclude TDOC’s ability to follow the Protocol to the letter
in practice, and there is no formal process for determining if and when TDOC should deviate from
the Protocol. The most egregious deviation seen by Butler Snow is the failure to test the LIC for
endotoxins (and potency in Mr. Irick’s case). The Drug Procurer indicated that they consulted the
Pharmacy Owner when drafting the July 2018 Protocol. The similarities in language used in the
revised January 2018 Protocol and the Pharmacy Services Agreement relating to same corroborate
the Drug Procurer’s recollection; however, Butler Snow has not uncovered any written

153

July 2018 Protocol, Exhibit 20 at 35.

154

Directions for Unpacking and Storage, Exhibit 23.
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BU T L E R I SNOW
communications between the Drug Procurer and the Pharmacy Owner regarding changes to the
Protocol between January and July 2018. Similarly, Butler Snow has found no evidence that the
current Protocol was ever sent to the Pharmacy. Instead, it appears that the Drug Procurer only
sent the six-page drafts of sections regarding the chemicals used, their set-up and preparation, and
the sequence and administration of the chemicals during the process of preparing the initial January
2018 iteration of the Protocol.

Both the Pharmacy Owner and Drug Procurer shared a misunderstanding of endotoxin
testing, specifically whether such testing is included in sterility testing, and based on this
misunderstanding, it appears neither consulted the Pharmacist on this topic in the course of
discussing the July 2018 Protocol. Crucially, the Pharmacy never received a copy of these
revisions or a complete copy of the July 2018 Protocol from TDOC, and the Pharmacist was never
informed that the Protocol requires testing for potency, sterility, and endotoxins.
Other examples include the storage of the LIC, as well as TDOC’s efforts to have LIC on
hand even if the condemned has chosen electrocution as the method of execution. This practice
began after the execution of Mr. Zagorski, but at least one TDOC employee indicated that the
decision to have LIC on hand as a backup method is not required by the Protocol. Another example
is in the disposal of expired LIC. Under the Protocol, the LIC is to be disposed of upon expiration
by hazardous waste pick-up. However, inspections are only required to be done on a semi-annual
basis, and on at least one occasion, LIC were disposed of that had been expired for several
months.155 With only semi-annual inspections, it is possible that expired LIC may be sitting for
months before being disposed of in accordance with the Protocol, which increases the possibility
of expired LIC being used inadvertently during an execution.

At least one TDOC employee indicated that when reviewed by a person familiar with the
actual process followed during an execution, the Protocol is not strictly followed because it is
inaccurate. Timing of events during execution was specifically noted as an area of the Protocol
that needed to be examined and revised.

155

Dep. Tr. of Warden Tony Mays at 193:25-196:25, attached hereto as Exhibit 112.
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BU T L E R I S

3. No Checks and Balances

There are no internal policies to ensure the Protocol is followed. Deviations occur, and
although such deviations may ensure compliance with USP guidelines in the context of
compounded LIC, this does not change the fact that the Protocol is not being followed.
Commissioners Parker and Helton both indicated that it is ultimately their responsibility to ensure
the Protocol is being followed, but to do so, a more rigorous review system must be put in place
to ensure accountability. Several individuals referenced TDOC’s general preference to have
limited documentation and a hesitance to make changes to the Protocol, but the overall sense is
that the Protocol needs to be reviewed to ensure that it is consistent in all aspects.
Furthermore, there is no structured review process. Members of the Execution Team156 are
required to review the Protocol annually once they become members of the Execution Team, but
there is no verification process. According to the Protocol, the Warden or his designee holds an
annual class to review the Protocol, but this training was not mentioned during Butler Snow’s
interviews with TDOC employees. Some RMSI training records identify the topic of training as
“Protocol” via “lethal injection” or “electrocution,” which may be a reference to the abovereferenced class. When asked, some individuals stated they review the entire Protocol multiple
times a year, and many indicated that they review portions of the Protocol when needed. It is
imperative that all individuals involved understand what is required under the Protocol and how
to meet those requirements. See recommendations below for how to improve this process.

156

Under the Protocol, the Execution Team consists of the Warden, Associate Warden of Security,
Executioner, IV Team, Extraction Team, Death Watch Team, Lethal Injection Recorder, Facility
Maintenance Supervisor, ITS Security Systems Technician(s), and Escort Officers. July 2018 Protocol at
32.
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BU TLE R I SNOW
D. TDOC Staffing Considerations

Butler Snow also attended one of the monthly lethal injection training sessions to observe
the TDOC staff’s involvement in the execution process. This allowed the investigative team to
assess (1) the staff’s expertise in carrying out lethal injection executions and (2) their ability to
comply with the current Protocol. Butler Snow notes that all TDOC training participants appeared
to be extremely professional, serious, dedicated and committed.

As far as the failure to test the LIC for endotoxins, there were no checks and balances in
place to ensure testing occurred. Butler Snow’s investigation revealed that neither the Pharmacy
nor the Pharmacist ever received a full copy of the July 2018 Protocol, or even a partial copy that
spoke to the testing requirements. Only one TDOC employee—the Drug Procurer—received the
testing reports from the Pharmacy, and as a result, no one else had any insight into whether the
LIC were prepared and tested in accordance with the Protocol. It should be noted that the Drug
Procurer does not have a medical or pharmaceutical background, and as a result, they do not have
any formal training that would aid them in understanding testing reports or assessing which tests
are necessary for compounded LIC. It should be further noted that there is no Drug Procurer job
description or list of duties stating that they are responsible for ensuring the LIC are properly tested
in accordance with the current Protocol. Even so, a plain reading of the third-party lab reports
indicates that only one endotoxin test occurred, and that was in May 2018. The fact of the matter
is not one TDOC employee made it their duty to understand the current Protocol’s testing
requirements and ensure compliance with same. And, based upon information provided during
investigative

interviews,

the

Former

Commissioner;

Interim

Commissioner;

Deputy

Commissioner/General Counsel; and Drug Procurer were in the best positions to ensure
compliance with the Protocol.

While medical training may not be strictly necessary to perform the roles required for
executions, it is certainly beneficial. Members of the Execution Team receive some medical
training on how to start IVs, but other instruction on preparing and delivering the LIC during an
execution came via instructions and a phone call with the Pharmacy. The Pharmacy Owner recalled
that their impression from that phone call was that the members of the Execution Team they spoke

BU T L E R I SNOW
with were inexperienced in preparing syringes for injection. Neither the Executioner nor the IV
Team Member recalled this phone call at the time of this Investigation. Even though the
Executioner157 has no formal healthcare training, they have participated in 13 executions for the
state of Tennessee and have observed an execution in at least 1 other state. They learned how to
fulfill their role primarily through on-the-job training and are very experienced at this point in
time. It would be difficult to find another individual, however, with this experience and/or medical
training to perform executions, because of the Hippocratic oath. Accordingly, in the event that this
individual leaves TDOC, their does not appear to be anyone in place prepared or qualified to
assume this role.

Additionally, placing the onus of finding LIC and verifying that the LIC are fit for use per
the Protocol and USP guidelines is an enormous task to place on one individual, especially when
they have other roles to fill and particularly when they are given zero guidance on how to carry
out these tasks. Moreover, this method does not allow for any checks and balances whatsoever.
Putting all of this responsibility on one person seems like an abdication of responsibility by TDOC
leadership and the reason for the failures to comply with the current Protocol cited in this Report.
See the recommendations below for how to remedy this issue.

IV.

Investigative Findings and Recommendations
As independent investigators, Butler Snow conducted a comprehensive review of the

available and relevant evidence concerning the circumstances which led Governor Lee to issue a
reprieve in connection with the April 21, 2022, scheduled execution of Mr. Smith. In addition to
this issue, the investigative team also (1) examined Tennessee’s Lethal Injection Protocol and any
deviations from same prior to April 21 and (2) determined the extent of TDOC’s staff’s
responsibility relating to these issues. As previously stated, the investigative findings are primarily
based upon the information gleaned through witness interviews as well as an extensive review of
thousands of pages of documents and/or data. While the interviews were very insightful, they

157

The Executioner is not involved in the testing of the LIC but is aware of the requirement by virtue of the
Protocol.
38

BU TLE R I SNOW
further showed the absence of adequate expertise, guidance, and counsel either enlisted by or
provided to TDOC in connection with Tennessee’s lethal injection process. Instead, TDOC
operated in a task-oriented, tunnel-vision manner that failed to appreciate the interwoven nature of
the lethal injection process as a whole.
A.

Investigative Findings

Based on the evidence obtained in the investigation, Butler Snow has made the following
findings:
1. Circumstances that led to testing the lethal injection chemicals for only potency and
sterility but not endotoxins [in connection with] preparing for the April 21 execution


There is no evidence that any failure to test the lethal injection chemicals for endotoxins in
connection with Mr. Smith’s scheduled execution on April 21 was intentional.



There is no evidence that, when the State of Tennessee revised its lethal injection protocol
in 2018, any employee ever informed the pharmacy tasked with testing Tennessee’s lethal
injection chemicals that it should conduct an endotoxin test on all lethal injection
chemicals—until the eve of Mr. Smith’s scheduled execution on April 21.



2. Clarity of the lethal injection process manual that was last updated in 2018, and
adherence to testing policies since the update


There evidence shows that the lethal injection chemicals used in the August 9, 2018,
execution of Mr. Billy Ray Irick (“Mr. Irick”) were not tested for endotoxins. The evidence
further shows that the Midazolam used during Mr. Irick’s execution was not tested for
potency.



The evidence shows that, although Edmund Zagorski (“Mr. Zagorski”) was executed via
electrocution on November 1, 2018, the lethal injection chemicals prepared in the event
39

BU TLE R I SNOW
Mr. Zagorski changed his mind and opted to be executed by lethal injection were not tested
in accordance with Tennessee’s lethal injection protocol. The lethal injection chemicals
were not tested for endotoxins and failed the potency testing.




The evidence shows that the lethal injection chemicals used in the May 16, 2019, execution
of Mr. Donnie Edward Johnson (“Mr. Johnson”) were not tested for endotoxins.



3. TDOC staffing considerations


The evidence shows that TDOC leadership placed an inordinate amount of responsibility
on the Drug Procurer without providing much, if any, guidance; help; or assistance.
Instead, TDOC leadership viewed the lethal injection process through a tunnel-vision,
result-oriented lens rather than provide the necessary guidance and counsel to ensure that
Tennessee’s lethal injection protocol was thorough, consistent, and followed.
B.

Recommendations

The instant investigation has helped bring to light issues that have impacted TDOC’s ability
to comply with Tennessee’s Lethal Injection Protocol since it was put in place in 2018. As a result,

BU TLE R I SNOW
Butler Snow makes the following recommendations for corrective action, further investigation, or
training:


Consider hiring a full-time employee or retaining a consultant with a pharmaceutical
background to provide guidance in connection with the lethal injection process.
 Conduct an exhaustive review of the current Protocol.
 Review the current Protocol’s testing requirements.
 Establish testing guidelines for any compounded LIC with procedures for
confirming that the appropriate tests are being performed.
 Establish a procedure for storing and maintaining test results.
 Establish a procedure for storing and maintaining LIC, including recommendations
regarding suitable equipment for storage.
 Assist with locating LIC sources and communicating pertinent information to same.



Ensure that a copy of any current or future version of the TDOC Protocol is provided to
the LIC provider.



Evaluate the roles and outline the duties of all TDOC employees, as well as any third
parties, tasked with participating in the lethal injection process.



Consider hiring a full-time employee or retaining a consultant with a healthcare
background to provide scheduled guidance and training to the Execution Team.
 Determine whether any Execution Team members should be required to obtain any
certifications and/or licenses.



Establish a team/committee to review all relevant testing data prior to each scheduled
execution to ensure that there are no deviations from the Protocol.
 Consider incorporating deadlines to obtain testing results in sufficient time to
ensure that failing LIC are not made available or used during a scheduled execution.
 Consider annual audits to ensure compliance and to evaluate Protocol efficiencies
and best practices.

BU T L E R I S

Appendix

ADDITIONAL DOCUMENTS PROVIDED/REVIEWED
Documents from TDOC
1.

Prescription orders for lethal drugs

2017-2018 Handwritten inventory for lethal drugs

11/15/2018 Inventory for lethal injection supplies

12/20/2017 Inventory for lethal drugs

11/1/2019 Inventory for lethal drugs

Research re compounding pharmacies and compounded drug products

12/20/2017 Inventory for lethal drugs

Handwritten lethal drug inventory and storage pictures

2022 Handwritten inventory for lethal drugs

10.

11/30/2020 Inventory for lethal injection supplies

11.

2018-2022 [Lab] Validation and Lab Reports for drugs

12.

Handwritten notes re drug supplier status and maintenance

13.

Handwritten notes re court and lethal drug storage and suppliers

14.

Vendor list for Fentanyl and Midazolam manufacturers

15.

Cardinal Health list of restricted products to Unqualified/incarceration
facility customers

16.

4/25/2018 Letter from Alvogen rejecting use of its drugs in lethal injection

17.

Handwritten notes re status of lethal drug suppliers

18.

Handwritten notes re lethal drugs and suppliers

19.

12/20/2017 Fax cover from [Drug Procurer] to [Pharmacy] (no enclosure)

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20.

11/27/2017 [Pharmacy] Specialty Pharmacy, LLC Pharmacy Services
Agreement

21.

[Pharmacy] 2017 invoices

22.

[Pharmacy] Formula Worksheets

23.

10/2018 Medical supplies purchased from Moore Medical

24.

Intravenous Training documents

25.

Draft Memo re project to search for new source of Pentobarbital and case

26.

Compounding pharmacy search

27.

Handwritten notes re compounding pharmacy

28.

Research re compounded drug products

29.

Research re compounding pharmacies search

30.

Compounded drugs sterility, potency and endotoxin requirements and US
Pharmacopeial Convention guidelines

31.

Handwritten notes re lethal drugs

32.

Handwritten notes re lethal drugs

33.

Research re clinical pharmacology for lethal drugs

34.

Research re lethal drugs

35.

Research re DEA and importing controlled substances

36.

List of inmates

37.

4/11/2019 Letter from Debra Inglis to Kelley Henry (federal public
defender) re Johnson Affidavit re Method of Execution

38.

8/23/2019 Email from Charlotte Davis (AAG) encl Nicholas Sutton stay
pleading

39.

4/20/2022 Oscar Smith Spiritual Advisor Attendance to Execution form

40.

Oscar Smith movement and execution planning

BU TLE R I SNOW
41.

Litigation hold re evidence intended for Oscar Smith’s execution

42.

3/16/2022 Fax from [Drug Procurer] to [Pharmacist] re John Moody (no
enclosure)

43.

2017 TDOC Controlled Substance Registration Certificate

44.

TDOC payments to drug suppliers

45.

TDOC Lethal Injection Manual rev 7/5/2018

46.

Public records requests

47.

Tony Parker’s Third Supplemental Response to Plaintiff’s First Set of
Interrogatories

48.

1/24/2019 Return receipt card from Debra Inglis to Jessica Johnson
(investigator)

49.

4/4/2017 Agreed (Pharmacy) Board Order for [Pharmacist]

50.

9/1/2016 Letter from (unknown) to (unknown) re authorization to dispense
prescriptions for Schedule II Controlled substances

51.

2017 Hotel invoices for [Drug Procurer]

52.

Handwritten notes re condition of body after executions

53.

Handwritten notes re Protocol A

54.

5/10/22 Email, Subject Fwd: Delegated Authorities for Execution Fys 1822

55.

6/30/2022 Email, Subject RE: Documents

56.

6/23/2022 Email, Subject Fwd: Oscar Smith's Execution

57.

6/23/2022 Email, Subject {NO SUBJECT}

58.

6/23/2022 Email, Subject {NO SUBJECT}

59.

6/3/2022 Email, Subject {NO SUBJECT}

60.

6/23/2022 Email, Subject FW: Oscar Frank Smith

BU TLE R I SNOW
61.

6/23/22 Email, Subject FW: Oscar Frank Smith

62.

6/22/22 Email, Subject Secured Document

63.

5/25/2022 Email, Subject [secure email]

64.

5/12/2022 Email, Subject [EXTERNAL] RE: documents

65.

5/12/2022 Email, Subject [EXTERNAL] RE: documents

66.

5/12/2022 Email, Subject [EXTERNAL] documents

67.

5/10/2022 Email, Subject FW: Reprieve

68.

5/2/2022 Email, Subject RE: [secure email]

69.

4/28/2022 Email, Subject Screenshot 2022-04-28 at 7.04.54 AM

70.

4/28/2022 Email, Subject Screenshot 2022-04-28 at 7.04.18 AM

71.

4/27/2022 Email, Subject Screenshot 2022-04-27 at 12.11.37 PM

72.

4/27/2022 Email, Subject Screenshot 2022-04-27 at 12:10.07 PM

73.

4/24/2022 Email, Subject RE: Privileged and Confidential - Document
Request

74.

4/24/2022 Email, Subject RE: Privileged and Confidential - Document
Request

75.

4/24/2022 Email, Subject RE: Privileged and Confidential - Document
Request

76.

4/24/2022 Email, Subject RE: Privileged and Confidential - Document
Request

77.

4/24/2022 Email, Subject FW: Privileged and Confidential - Document
Request

78.

4/23/2022 Email, Subject RE: Privileged and Confidential - Document
Request

79.

4/22/2022 Email, Subject [EXTERNAL] RE: testing docs

80.

4/22/2022 Email, Subject [EXTERNAL] testing docs

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81.

4/22/2022 Email, Subject RE: Privileged and Confidential - Document
Request

82.

4/21/2022 Email, Subject Privileged and confidential - Document Request

83.

4/21/2022 Email, Subject Order setting date

84.

4/21/2022 Email, Subject Reprieve

85.

4/12/2022 Email, Subject RE: [EXTERNAL] RE: Order

86.

4/12/2022 Email, Subject [EXTERNAL] RE: Order

87.

4/12/2022 Email, Subject [EXTERNAL] RE: Order

88.

4/10/2022 Email, Subject Rimmer Letter

89.

4/8/2022 Email, Subject [secure email]

90.

4/7/2022 Email, Subject [secure email]

91.

4/6/2022 Email, Subject [EXTERNAL] RE: Order

92.

3/16/2022 Email, Subject [EXTERNAL] RE: Order

93.

3/16/2022 Email, Subject [EXTERNAL] RE: Order

94.

3/16/2022 Email, Subject Order

95.

3/11/2022 Email, Subject RE: Secured Documents

96.

3/10/2022 Email, Subject RE: Secured Documents

97.

3/10/2022 Email, Subject Secured Documents

98.

2/24/2022 Email, Subject FW: 00218364 SUTTON, GARY W. order
setting execution date

99.

2/10/2022 Email, Subject Training Docs

100.

1/13/2022 Email, Subject Documentation (special)

101.

1/4/2022 Email, Subject [EXTERNAL] FW: Invoice 20211130TN from
[Pharmacy] Specialty Pharmacy LLC

102.

11/29/2021 Email, Subject RE: [EXTERNAL] RE: Order

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103.

11/24/2021 Email, Subject RE: [EXTERNAL] RE: Order

104.

11/22/2021 Email, Subject RE: [EXTERNAL] RE: Further Discovery

105.

11/1/2021 Email, Subject RE: Docs

106.

11/19/2021 Email, Subject RE: Docs

107.

11/18/2021 Email, Subject RE: [EXTERNAL] RE: Further Discovery

108.

11/17/2021 Email, Subject RE: [EXTERNAL] RE: Further Discovery

109.

11/9/2021 Email, Subject RE: [EXTERNAL] RE: Further Discovery

110.

11/9/2021 Email, Subject RE: [EXTERNAL] RE: Further Discovery

111.

11/9/2021 Email, Subject Further Discovery

112.

11/5/2021 Email, Subject RE: [EXTERNAL] RE: Order

113.

11/5/2021 Email, Subject Re: [EXTERNAL] RE: Order

114.

11/5/2021 Email, Subject [EXTERNAL] RE: Order

115.

11/5/2021 Email, Subject FW: Rimmer 110874 Order

116.

11/5/2021 Email, Subject Order

117.

11/5/2021 Email, Subject FW: [EXTERNAL] Court News: Supreme Court
Sets Two Execution Dates

118.

11/4/2021 Email, Subject RE: Products

119.

11/2/2021 Email, Subject RE: Products

120.

11/2/2021 Email, Subject RE: Products

121.

11/2/2021 Email, Subject RE: Products

122.

10/29/2021 Email, Subject Products

123.

10/15/2021 Email, Subject Training Documents for October

124.

10/12/2021 Email, Subject [EXTERNAL] RE: Discovery Request

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125.

10/12/2021 Email, Subject Discovery Request

126.

9/29/2021 Email, Subject Re: [EXTERNAL] RE: Order

127.

9/29/2021 Email, Subject [EXTERNAL] RE: order

128.

9/29/2021 Email, Subject [EXTERNAL] FW:

129.

9/29/2021 Email, Subject [EXTERNAL] RE: Invoice 20210901 TN from
[Pharmacy] Specialty Pharmacy LLC

130.

9/29/2021 Email, Subject RE: Invoice 20210901 TN from [Pharmacy]
Specialty Pharmacy LLC

131.

9/23/2021 Email, Subject Documents from this month

132.

9/23/2021 Email, Subject Training documents

133.

9/20/2021 Email, Subject [EXTERNAL] RE: Twoish Things

134.

9/20/2021 Email, Subject [EXTERNAL] RE: Twoish Things

135.

9/20/2021 Email, Subject Fwd: Twoish Things

136.

9/17/2021 Email, Subject [EXTERNAL] RE: kci inventory

137.

9/17/2021 Email, Subject RE: kci inventory

138.

9/17/2021 Email, Subject RE: kci inventory

139.

9/17/2021 Email, Subject [EXTERNAL] kci inventory

140.

9/17/2021 Email, Subject [EXTERNAL] RE: midazolam inventory

141.

9/17/2021 Email, Subject RE: midazolam inventory

142.

9/17/2021 Email, Subject [EXTERNAL] midazolam inventory

143.

9/16/2021 Email, Subject [EXTERNAL] FW: Invoice 20210901TN from
[Pharmacy] Specialty Pharmacy LLC

144.

9/16/2021 Email, Subject [EXTERNAL] FW: Invoice 20210906AF from
[Pharmacy] Specialty Pharmacy LLC

145.

9/15/2021 Email, Subject RE: Thursday

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146.

9/15/2021 Email, Subject Thursday

147.

7/28/2021 Email, Subject [EXTERNAL] RE: Discovery Items

148.

7/26/2021 Email, Subject [EXTERNAL] RE: Deposition

149.

7/15/2021 Email, Subject RE: [EXTERNAL] travel logistics

150.

7/15/2021 Email, Subject RE: [EXTERNAL] travel logistics

151.

7/15/2021 Email, Subject [EXTERNAL] travel logistics

152.

7/15/2021 Email, Subject [EXTERNAL] RE: King Depo Prep

153.

7/9/2021 Email, Subject [EXTERNAL] RE: King Depo Prep

154.

7/9/2021 Email, Subject [EXTERNAL] RE: King Depo Prep

155.

7/6/2021 Email, Subject [EXTERNAL] RE: AVAILABILITY

156.

7/6/2021 Email, Subject RE: Training logs

157.

7/6/2021 Email, Subject [EXTERNAL] RE: AVAILABILITY

158.

7/6/2021 Email, Subject [EXTERNAL] FW: AVAILABILITY

159.

7/1/2021 Email, Subject Letter from Federal Public Defenders Office

160.

6/22/2021 Email, Subject [EXTERNAL] AVAILABILITY

161.

6/4/2021 Email, Subject Updated document

162.

6/2/2021 Email, Subject Re: 2 of 2

163.

6/2/2021 Email, Subject 2 of 2

164.

6/2/2021 Email, Subject 1 of 2

165.

4/14/2021 Email, Subject confidential documents

166.

4/12/2021 Email, Subject confidential documents

167.

3/1/2021 Email, Subject Confidential

168.

1/26/2021 Email, Subject [EXTERNAL] Fw: Invoice TN20210126 from
[Pharmacy] Pharmacy LLC

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169.

1/14/2021 Email, Subject RE: Training Rosters

170.

1/13/2021 Email, Subject Additional rosters from today

171.

11/18/2020 Email, Subject [EXTERNAL] Fw: Invoice TN20200511 from
[Pharmacy] Specialty Pharmacy LLC

172.

9/24/2020 Email, Subject FW: Letter from VP Witmer w/B. Braun Medical

173.

9/24/2020 Email, Subject FW: Letter from General Counsel Wohlfeil
w/Meitheal Pharmaceuticals

174.

9/14/2020 Email, Subject Fwd: Letter from VP McDonnel w/Sandoz, Inc.

175.

8/18/2020 Email, Subject RE: Request

176.

8/13/2020 Email, Subject [EXTERNAL] requested info

177.

8/12/2020 Email, Subject {NO SUBJECT}

178.

7/28/2020 Email, Subject [EXTERNAL] Fw: Invoice TN202000728 from
[Pharmacy] Specialty Pharmacy LLC

179.

7/22/2020 Email, Subject [EXTERNAL] potency

180.

4/15/2020 Email, Subject [EXTERNAL] February invoice

181.

12/20/2019 Email, Subject [EXTERNAL] New Invoice

182.

12/19/2019 Email, Subject FW: Question

183.

12/9/2019 Email, Subject [EXTERNAL] New Invoice

184.

12/5/2019 Email, Subject [EXTERNAL] Report

185.

11/26/2019 Email, Subject [EXTERNAL] Lab results

186.

11/21/2019 Email, Subject [EXTERNAL] Alternatives

187.

11/20/2019 Email, Subject [EXTERNAL] see attached

188.

10/30/2019 Email, Subject [EXTERNAL] RE: API

189.

9/19/2019 Email, Subject [EXTERNAL] Invoices

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190.

8/15/2019 Email, Subject [EXTERNAL] Scanned from a Xerox
[Pharmacy] Pharmacy.pdf

191.

8/12/2019 Email, Subject [EXTERNAL] 2019-18034.pdf

192.

8/12/2019 Email, Subject [EXTERNAL] ETX-190806-0007LabReport.pdf

193.

8/9/2019 Email, Subject [EXTERNAL] results

194.

8/8/2019 Email, Subject [EXTERNAL] Suitability Test

195.

8/8/2019 Email, Subject [EXTERNAL] KCI

196.

8/8/2019 Email, Subject [EXTERNAL] RE: kci protocol

197.

8/7/2019 Email, Subject [EXTERNAL] Invoice

198.

7/31/2019 Email, Subject [EXTERNAL] Report

199.

7/29/2019 Email, Subject [EXTERNAL] RE: Declaration

200.

7/26/2019 Email, Subject RE: Declaration

201.

7/24/2019 Email, Subject [EXTERNAL] Report

202.

7/10/2019 Email, Subject RX

203.

7/2/2019 Email, Subject [EXTERNAL] FW: kci protocol

204.

6/26/2019 Email, Subject kci protocol

205.

6/26/2019 Email, Subject Proposed Alternative

206.

6/26/2019 Email, Subject [EXTERNAL] http://leucadiapharma.com/anticapital-punishment-statement/

207.

6/26/2019 Email, Subject KCI

208.

6/26/2019 Email, Subject [EXTERNAL] KCI Protocol

209.

5/13/2019 Email, Subject FW: Midazolam

210.

5/13/2019 Email, Subject RE: Invoice Check

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211.

5/9/2019 Email, Subject RE: Invoices

212.

5/9/2019 Email, Subject Invoices

213.

5/9/2019 Email, Subject report

214.

4/29/2019 Email, Subject Potency report

215.

4/2/2019 Email, Subject follow up

216.

2/26/2019 Email, Subject New Invoice

217.

2/14/2019 Email, Subject RE: Summary of Invoices

218.

11/7/2018 Email, Subject RE: Payments [secure email]

219.

11/6/2018 Email, Subject Open Invoices

220.

11/2/2018 Email, Subject Invoice

221.

10/31/2018 Email, Subject Invoice

222.

10/10/2018 Email, Subject Final Report

223.

8/27/2018 Email, Subject Our friend Wally

224.

8/24/2018 Email, Subject Fwd: Tennessee License

225.

8/23/2018 Email, Subject Fwd:

226.

8/16/2018 Email, Subject TN81618

227.

8/15/2018 Email, Subject Invoice

228.

8/8/2018 Email, Subject Log

229.

8/6/2018 Email, Subject USP 71

230.

7/25/2018 Email, Subject updated invoice

231.

7/23/2018 Email, Subject Shipping SOP

232.

7/18/2018 Email, Subject RE: sample RX

233.

7/17/2018 Email, Subject sample Rx

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234.

7/16/2018 Email, Subject Protocol

235.

7/15/2018 Email, Subject Fwd: Certificates

236.

7/12/2018 Email, Subject Testing report

237.

7/9/2018 Email, Subject RE: Invoices

238.

7/9/2018 Email, Subject Invoices

239.

7/9/2018 Email, Subject {NO SUBJECT}

240.

7/5/2018 Email, Subject Invoice

241.

7/3/2018 Email, Subject FW: ACHC Accreditation Decision_60062
[Pharmacy] Specialty Pharmacy

242.

6/22/2018 Email, Subject {NO SUBJECT}

243.

6/20/2018 Email, Subject Product Inquiry

244.

4/5/2018 Email, Subject FW: Invoices

245.

1/22/2018 Email, Subject List of restricted drugs

246.

4/9/2018 Vendor Letter

247.

12/4/2017 TX Case Order

248.

5/6/2020 TPRA Final Response Letter General

249.

1/10/2017 TN DEA Lic

250.

Summary re draft of information re TDOC's search for Pentobarbital

251.

10/18/2019 Roane v. Gonzales_Govt's Response to Motion for Preliminary
Injunction

252.

4/9/2018 Removal of Vendor Information Request

253.

2017 Receipts – [Drug Procurer]’s hotel invoices

254.

Motion Responses - Word document providing responses to questions

255.

4/9/2018 Email, Subject FW: Removal of Vendor Information Request

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256.

2018-2019 Electric chair testing logs

257.

Draft Bill on election timeframe

258.

9/1/2017 Death Row Report

259.

7/1/2017 Delegated Authority for Tennessee’s execution related services

260.

9/1/2017 D.R. Offenders with Execution Date

261.

9/1/2017 D.R. Offender Demographics

262.

9/1/2017 D.R. by Offender TOMIS ID

263.

9/1/2017 D.R. by Offender Last Name

264.

CONSULTANT SERVICES AGREEMENT

265.

CentralPharmacyLicense5661

266.

4/13/2022 handwritten inventory log of lethal drugs

267.

4/21/20.22 handwritten inventory log of lethal drugs

268.

9/7/2017 Email, Subject Updtae

269.

12/4/2017 Email confirming vecuronium is the only chemical requiring
reconstitution

270.

9/6/2017 Email, Subject Touch Base

271.

9/21/2017 Email, Subject Status Update

272.

8/30/2021 Letter from Sandoz

273.

12/5/2017 Redacted email discussing supplier for lethal drugs

274.

9/7/2017 Email, Subject RE: “Updtae”

275.

9/7/2017 Email, Subject RE: “Updtae”

276.

9/7/2017 Email, Subject RE: “Updtae”

277.

10/26/2017 Email, Subject RE: Additional Info

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278.

9/20/2017 Email, Subject Is there a good time for me to give you a buzz
today? Thanks

279.

9/21/2017 Email, Subject Fwd: Status Update

280.

6/18/2018 Letter from Fresenius Kabi USA, LLC

281.

1/22/2018 PDF of emails

282.

2017 PDF of emails and attachments

283.

2017 PDF of emails and attachments

284.

6/18/2018 Letter from Athenex

285.

2018, 2019, 2020 and 2022 lab reports for lethal drugs

286.

Draft of Midazolam storage and preparation instructions with comment
from [Drug Procurer]

287.

Blank Pharmacy Services Agreement form in notepad

288.

7/23/2018 Letter to Billy Ray Irick from Tony Mays notifying of execution
date and method

289.

Potassium Chloride preparation instructions

290.

Execution Procedures for Lethal Injection, rev 7/11/2016

291.

Execution Procedures for Lethal Injection in notepad

292.

Execution Procedures for Lethal Injection, rev 6/25/2015

293.

12/11/2017 Email, Subject FW: Lemaricus Davidson (#328954) Order
Granting Stay of Execution

294.

Execution Procedures for Electrocution, rev 7/11/2016

295.

Lethal Injection Execution Manual Execution Procedures for Lethal
Injection, rev 7/5/2018

296.

Lethal Injection Execution Manual Execution Procedures for Lethal
Injection, rev 7/5/2018

297.

Blank Affidavit Concerning Method of Execution and Affidavit to Select
Defense Counsel Witness to Execution

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298.

Lethal Injection Execution Manual Execution Procedures for Lethal
Injection, rev 7/5/2018

299.

Handwritten inventory logs of lethal drugs from 7/27/2018 – 8/14/2019

300.

Handwritten inventory logs of lethal drugs from 5/15/2019 – 8/14/2019

301.

Lethal Injection Execution Manual Execution Procedures for Lethal
Injection, rev 1/8/2018

302.

Draft Execution Procedures for Electrocution, rev 6/26/2014

303.

Draft Execution Procedures for Electrocution, rev 6/26/2014

304.

Draft Execution Procedures for Electrocution, rev 6/26/2014

305.

Execution Procedures for Electrocution, rev 3/13/2017

306.

Redacted Execution Procedures for Electrocution, rev 3/13/2017

307.

Execution Procedures for Lethal Injection, rev 9/22/2014

308.

Execution Procedures for Lethal Injection, rev 9/22/2014

309.

Execution Procedures for Lethal Injection, rev 9/18/2014

310.

Execution Procedures for Lethal Injection, rev 9/18/2014

311.

Execution Procedures for Lethal Injection

312.

Execution Procedures for Lethal Injection

313.

Redacted Execution Procedures for Electrocution

314.

Draft Execution Procedures for Electrocution, rev 6/26/2014

315.

Draft Execution Procedures for Electrocution, rev 6/26/2014

316.

Draft Execution Procedures for Electrocution

317.

Draft Execution Procedures for Electrocution

318.

Draft Execution Procedures for Electrocution

319.

Draft Execution Procedures for Electrocution

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320.

Draft of amendment to TCA 40-23-114 - relative to election of the method
of execution

321.

Draft of amendment to TCA 40-23-114 - relative to election of the method
of execution

322.

PDF of Draft of amendment to TCA 40-23-114 with notes - relative to
election of the method of execution with the Warden's primary role and
Affidavit Concerning Method of Execution from TDOC's Execution
Procedures for Lethal Injection

323.

11/15/2018 Order for supplies

324.

11/3/2020 Order for supplies

325.

3/1/2022 Email, Subject RE: 3680_001.pdf

326.

Orders setting execution dates for Donald Ray Middlebrooks, Gary Wayne
Sutton and Byron Lewis Black

327.

12/11/2019 Order Denying Motion and Order Staying execution re Abu Ali
AbdurRahman

328.

11/16/2018 Order setting execution date re Abu Ali AbdurRahman

329.

7/1/2019 Order setting execution date re Abu Ali AbdurRahman

330.

Orders setting execution dates and sealed order for transport re Byron
Lewis Black

331.

2/24/2020 Order setting execution date re Byron Lewis Black

332.

11/1/2019 Potassium Chloride and Midazolam prescriptions for Leroy Hall

333.

11/5/2019 Letter to Lee Hall from Tony Mays notifying of execution date
and method

334.

9/26/2019 Letter from Kelly A. Gleason to Debra Inglis and Tony Mays
requesting to be present when method of execution is presented to Hall

335.

11/1/2019 Lidocaine HCL 2% prescription for Leroy Hall

336.

Visit logs, outlook scheduled meetings for visits, Special Visit Requests,
Request and Affidavit re disposition of belongings, personal property

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inventories and letters re presence at execution on 12/5/2019 for Lee Hall
(53 pages)
337.

Redacted TDOC Incident Report, Execution Recorder Checklist, Death
row watch logs and Record of staff visits for Lee Hall (51 pages)

338.

Unredacted TDOC Incident Report, Execution Recorder Checklist, Death
row watch logs and Record of staff visits for Lee Hall (51 pages)

339.

11/16/2018 Order setting execution date for Lee Hall

340.

7/10/2018 Amended Order setting execution date for Billy Ray Irick

341.

8/8/2018 Response to Motion for Leave to Serve Subpoena Duces Tecum
Instanter re Billy Ray Irick

342.

7/18/2018 Prescription for Midazolam for Billy Ray Irick

343.

7/23/2018 Letter to Billy Ray Irick from Tony Mays notifying of execution
date and method

344.

5/22/2018 Lab report for Midazolam suitability re Billy Ray Irick

345.

7/24/2018 Letter to Tennessee Attorney General and Billy Ray Irick's
attorneys enclosing the 7/23/2018 execution notification letter

346.

8/6/2018 Lab report for Midazolam sterility re Billy Ray Irick

347.

8/6/2018 Order denying Billy Ray Irick's motion to vacate execution date

348.

Dissent to 8/6/2018 Order

349.

Tennessee’s Brief in Opposition to Billy Ray Irick's application for stay of
execution

350.

Tennessee's Response to Billy Ray Irick's Petition for Writ of Habeas
Corpus and Application for a stay of execution

351.

5/25/2018 Lab report for Midazolam potency, endotoxins and sterility re
Billy Ray Irick

352.

5/14/2018 Lab report for Midazolam container closure integrity re Billy
Ray Irick

353.

8/6/2018 Gov. Haslam's statement that clemency not appropriate for Billy
Ray Irick

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354.

4/11/2019 Letter from Debra Inglis to Kelley J. Henry re presenting the
Affidavit re Method of Execution and notification letter to Donnie Johnson

355.

5/9/2019 Lab report for Midazolam potency and sterility re Donnie
Johnson

356.

4/17/2019 Midazolam prescription for Donnie Johnson

357.

5/1/2019 Letter to Donnie Johnson from Tony Mays notifying of execution
date and method

358.

4/11/2019 Letter from Debra Inglis to Kelley J. Henry re presenting the
Affidavit re Method of Execution and notification letter to Donnie Johnson

359.

4/26/2019 Lab report for Midazolam potency re Donnie Johnson

360.

11/16/2018 Order setting execution date re Donnie Johnson

361.

4/16/2019 Letter to Donnie Johnson from Tony Mays notifying of
execution date and method

362.

11/21/2018 Letter to David Miller from Tony Mays notifying of execution
date and method with waiver election

363.

11/9/2018 Letter to Stephen Kissinger from [Drug Procurer] in response to
correspondence

364.

11/16/2018 Midazolam prescription for David Miller

365.

11/21/2018 Letter to David Miller from Tony Mays notifying of execution
date and method with waiver election

366.

11/21/2018 Letter to David Miller from Tony Mays notifying of method of
execution by lethal injection due to waiver not being provided by deadline

367.

3/15/2018 Order granting amicus brief and denying Tennessee's Motion to
set an execution date prior to 6/1/2018 re David Miller

368.

3/15/2018 Order setting execution date for David Miller

369.

11/21/2018 Letter to David Miller from Tony Mays notifying of execution
date and method with waiver election

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370.

11/6/2018 Letter to Stephen Kissinger from Tony Mays enclosing
Affidavit Concerning Method of Execution for lethal injection waiver to be
presented to David Miller

371.

11/16/2018 Midazolam prescription for David Miller

372.

Blank Affidavit to Select Defense Counsel Witness to Execution

373.

11/27/2018 signed and completed Affidavit to Select Defense Counsel
Witness to Execution re David Miller and 11/27/2018 Letter from Tony
Mays to David Miller and Kissinger acknowledging receipt of Miller's
election waiving lethal injection and notifying that Miller will be executed
via electrocution.

374.

Copy of envelope to Tony Mays from David Miller

375.

11/23/2018 Handwritten note from David Miller waiving lethal injection
and electing electrocution

376.

11/8/2018 Letter to Tony Mays from Stephen Kissinger requesting
information re David Miller

377.

12/9/2019 Potassium Chloride and Midazolam prescription for Sutton

378.

2/4/2020 Letter to Nicholas Sutton from Tony Mays notifying of execution
date and method, Sutton waived lethal injection

379.

2/4/2020 Letter to Nicholas Sutton from Tony Mays notifying of execution
date and method via execution

380.

1/21/2020 Affidavit Concerning Method of Execution and Affidavit to
Select Defense Counsel Witness to Execution re Nicholas Sutton

381.

2/3/2020 Email, Subject Fwd: Sutton Update

382.

Day of Execution - Electrocution Execution Recorder Checklist for
Nicholas Sutton (11 pages)

383.

Death watch logs for Nicholas Sutton (40 pages)

384.

Letters notifying individuals of selection to witness the execution,
correspondence to Nicholas Sutton's attorney, correspondence regarding
attending execution, Inmate Inquiry form, Inventories of property,
notification letter, Affidavit Concerning Method of Execution, Cremation
form, Volunteer Application and certification for reverend, Outlook

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scheduled meetings with visitors, Visit request forms, Release form and
Staff visit logs re Nicholas Sutton (81 pages)
385.

11/16/2018 Order for execution for Nicholas Sutton

386.

Letter to Stephen West from Tony Mays notifying of execution date and
method

387.

5/4/2019 Email, Subject RE: contact information – re Stephen West

388.

7/12/2019 Potassium Chloride and Midazolam prescription for Stephen
West

389.

7/15/2019 Letter to Stephen West from Tony Mays notifying of execution
date and method

390.

7/18/2019 Lab report for Midazolam potency re Stephen West

391.

7/30/2019 Lab report for Midazolam sterility and potency re Stephen West

392.

7/15/2019 Affidavit to Select Defense Counsel Witness to Execution and
Affidavit Concerning Method of Execution re Stephen West

393.

7/12/2019 Potassium Chloride and Midazolam prescription for Stephen
West

394.

7/17/2019 Lab report for potassium chloride potency re Stephen West

395.

Redacted Letters notifying individuals of selection to witness the
execution, correspondence to Stephen West's attorney, Outlook scheduled
meetings with visitors, correspondence regarding attending execution and
inventory of personal belongings re Stephen West (66 pages)

396.

Letters notifying individuals of selection to witness the execution,
correspondence to Stephen West's attorney, Outlook scheduled meetings
with visitors, correspondence regarding attending execution and inventory
of personal belongings re Stephen West (66 pages)

397.

Redacted TDOC Incident Report, Day of Execution - Electrocution
Execution Recorder Checklist and Staff visit logs re Stephen West (22
pages)

398.

TDOC Incident Report, Day of Execution - Electrocution Execution
Recorder Checklist and Staff visit logs re Stephen West (22 pages)

399.

Redacted Death watch logs for Stephen West (42 pages)

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400.

Death watch logs for Stephen West (42 pages)

401.

11/16/2018 Order for execution for Stephen West

402.

8/6/2019 Sixth Circuit order affirming district court's order and denying
Stephen West's motion for a stay of execution

403.

11/16/2018 Order for execution for Charles Wright

404.

10/22/2018 Order for execution for Edmund Zagorski

405.

10/11/2018 Reprieve from Gov. Haslam until 10/21/2018 for Edmund
Zagorski

406.

9/11/2018 Email, Subject Zagorski forms

407.

Excel spreadsheet of Midazolam test results for sterility and potency for
Edmund Zagorski

408.

9/27/2018 Letter to Edmund Zagorski from Tony Mays notifying of
execution date and method

409.

10/9/2018 Letter to Kelley Henry from Debra Inglis advising Affidavit
ineffective and execution will proceed by lethal injection re Edmund
Zagorski

410.

10/9/2018 Letter to Kelley Henry from Debra Inglis advising Affidavit
ineffective and execution will proceed by lethal injection re Edmund
Zagorski

411.

10/10/2018 Defendants' Response to Plaintiffs' Motion for Temporary
Restraining Order re Edmund Zagorski

412.

9/21/2018 Midazolam prescription for Edmund Zagorski

413.

10/24/2018 Midazolam prescription for Edmund Zagorski

414.

10/24/2018 Midazolam prescription for Edmund Zagorski

415.

PDF of TCA Sec 39-16-201, policies and procedures for visits, visitation
application and forms, highlights re electronic devices

416.

PDF of TCA Sec 39-16-201, policies and procedures for visits, visitation
application and forms

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417.

9/27/2018 Letter to Edmund Zagorski from Tony Mays notifying of
execution date and method

418.

9/24/2018 Lab report for Midazolam potency re Edmund Zagorski

419.

8/30/2018 Letter from Kelley Henry re request for Edmund Zagorski not to
be presented with an Affidavit Concerning Method of Execution

420.

10/8/2018 Lab report for Midazolam sterility and potency re Edmund
Zagorski

421.

9/27/2018 Affidavit Concerning Method of Execution re Edmund Zagorski

422.

TDOC policies and procedures re Attorney Access to Inmates and blank
release

423.

7/22/2020 Email, Subject [EXTERNAL] potency – re Harold Wayne
Nichols

424.

7/1/2020 Potassium chloride and midazolam prescriptions for Harold
Wayne Nichols

425.

7/2/2020 Letter to Harold Wayne Nichols from Tony Mays notifying of
execution date and method with waiver election

426.

1/15/2020 order setting execution for Harold Wayne Nichols

427.

11/3/2021 order setting execution for Harold Wayne Nichols

428.

11/3/2020 Potassium chloride and Midazolam prescriptions for Pervis
Payne

429.

11/3/2020 Letter to Pervis Payne from Tony Mays notifying of execution
date and method with waiver election, Affidavit Concerning Method of
Execution and Affidavit to Select Defense Counsel Witness to Execution

430.

11/3/2020 Letter to Pervis Payne from Tony Mays notifying of execution
date and method with waiver election

431.

2/24/2020 Order setting execution for Pervis Payne

432.

4/11/2020 Letter to Michael Rimmer from Tony Mays notifying of
execution date and method with waiver election

433.

4/16/2021 Judgment affirming conviction and sentence and appeal
documents re Michael Rimmer

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434.

3/16/2022 Potassium Chloride and Midazolam prescriptions for Oscar
Smith

435.

3/16/2022 Potassium Chloride and Midazolam signed prescriptions for
Oscar Smith

436.

12/21/2020 Letter from Amy Harwell to Tony Mays re Oscar Smith's
objection to signing the Affidavit Regarding Method of Execution

437.

1/5/2021 Order staying Oscar Smith's execution date due to COVID-19

438.

3/21/2022 Letter to Oscar Smith from Tony Mays notifying of execution
date and method with waiver election

439.

Inventory of items preserved from 4/21/2022 execution preparation and
chemical preparation forms re Oscar Smith

440.

4/20/2022 Lab reports of Midazolam sterility and potency re Oscar Smith

441.

3/31/2022 Lab report of potassium chloride potency re Oscar Smith

442.

3/31/2022 Lab report of potassium chloride sterility re Oscar Smith

443.

4/20/2022 Non-Disclosure Agreement, Spiritual Advisor Attendance to
Execution of Death Sentence re Oscar Smith

444.

1/15/2020 order setting execution date for Oscar Smith

445.

4/17/2020 order setting execution date for Oscar Smith

446.

Orders setting execution dates re Oscar Smith

447.

Workman v Bredesen case, 486 F.3d 896 (2007)

448.

Opinion affirming trial court's judgment, trial court did not err in
dismissing Plaintiff's claims (3/28/2017) re Stephen West

449.

West v Schofield case, 460 S.W.3d 113 (2015)

450.

Ohio Execution Protocol Litigation - Opinion affirming district court's
granting of preliminary injunction enjoining Ohio's execution of 3 inmates
to allow further litigation re midazolam's efficacy before Ohio executes 3
inmates (4/6/2017)

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451.

Ohio Execution Protocol Litigation - Opinion affirming district court's
denial of Henness’ request to stay his execution (9/11/2019)

452.

Heckler v Chaney case, 470 U.S. 821 (1985)

453.

Glossip v Gross Resp Brief, Oklahoma's brief re whether a 3-drug lethal
injection protocol creates a substantial risk of severe pain due to
Midazolam use as first drug (4/8/2015)

454.

Glossip v Gross case, 135 S.Ct. 2726 (2015)

455.

Cook v Food and Drug Administration case, 733 F.3d 1 (2013)

456.

Bray v Lombardi case, 2017 WL 574909 (2/14/2017)

457.

AbdurRahman v Bredesen case, 181 S.W.3d 292 (10.17.2005)

458.

Method of Execution Act of 2015, A.C.A. Sect 5-4-617 - re Arkansas law

459.

6/4/2018 Email, Subject FW: Shults, No. CV-17-544 – re Arkansas law

460.

3/29/2018 - Wood Concurring Dissenting Opinion - Arkansas Supreme
Court dissent from majority's conclusion that the identity of drug
manufacturers is not protected under the confidentiality provisions of the
Method of Execution Act

461.

3/29/2018 - Majority Opinion - Arkansas Supreme Court opinion finding
that the identity of drug manufacturers is not protected under the
confidentiality provisions of the Method of Execution Act

462.

3/29/2018 - Kemp Concurring Dissenting Opinion - Arkansas Supreme
Court opinion concurring in part and dissenting in part to majority's
opinion

463.

April 2017 redacted text messages re acquiring lethal drugs produced in
Adbur Rahman v. Parker – Chancery Court proceedings

464.

6/5/2018 Deposition transcript of Tony Parker in Adbur Rahman v. Parker
– Chancery Court proceedings

465.

6/4/2018 Deposition transcript of Tony Mays in Adbur Rahman v. Parker –
Chancery Court proceedings

466.

7/7/2018 Plaintiffs' Response to Motion for Protective Order in Adbur
Rahman v. Parker – Chancery Court proceedings

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467.

8/13/2017 Redacted TDOC Lethal Injection Update PowerPoint
presentation advising on the current death row inmates, laws re executions
and efforts made to procure chemical to compound lethal drugs for
executions produced in Adbur Rahman v. Parker – Chancery Court
proceedings

468.

2/20/2018 Plaintiffs' First Set of Interrogatories to Defendants in Adbur
Rahman v. Parker – Chancery Court proceedings

469.

2/20/2018 Plaintiffs' First Request for Production of Documents in Adbur
Rahman v. Parker – Chancery Court proceedings

470.

Redacted April and July 2017 emails re procuring Pentobarbital produced
in Adbur Rahman v. Parker – Chancery Court proceedings

471.

Picture of the first page of article "Using pain to assess neurologic
response" produced in Adbur Rahman v. Parker – Chancery Court
proceedings

472.

5/7/2018 Order Granting in Part and Denying in Part Plaintiffs' Motion to
Compel in Adbur Rahman v. Parker – Chancery Court proceedings

473.

6/29/2018 Memorandum and Order Granting in Part and Denying in Part
Plaintiffs' Motion to Amend in Adbur Rahman v. Parker – Chancery Court
proceedings

474.

5/24/2018 Memorandum and Order Denying Motion for Protective Order
Seeking to Quash Parker and Mays Depositions But Issuing Limitations on
Time and Scope of Depositions; and Additional Orders on Deadlines on
Expert Disclosures and Defendants' Summary Judgment Filing in Adbur
Rahman v. Parker – Chancery Court proceedings

475.

7/3/2018 Orders: (1) Denying Plaintiffs' 7/2/2018 Motion to Reconsider;
(2) Permitting Offer of Proof at Trial; and (3) Denying Defendants' Motion
to Strike Second Amended Complaint and Submit Corrected Version in
Accordance with the Court's Order in Adbur Rahman v. Parker – Chancery
Court proceedings

476.

6/25/2018 Notice of Filing Exhibit in Support of Plaintiffs' Motion and
Memorandum of Law Regarding Defendants New Unwritten Protocol
Using Compounded High Risk Sterile Injectables Under Seal in Adbur
Rahman v. Parker – Chancery Court proceedings

477.

6/11/2018 Notice of Filing (Deposition of Commissioner Parker and
Warden Mays) in Adbur Rahman v. Parker – Chancery Court proceedings

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478.

Redacted handwritten notes re procuring Pentobarbital produced in Adbur
Rahman v. Parker – Chancery Court proceedings

479.

5/4/2018 Memorandum and Order Granting in Part and Denying in Part
Defendants' Motion to Dismiss in Adbur Rahman v. Parker – Chancery
Court proceedings

480.

5/29/2018 Defendants' Motion for Summary Judgment in Adbur Rahman v.
Parker – Chancery Court proceedings

481.

September 2017 redacted emails re ordering Midazolam, Vecuronium and
Potassium Chloride for a 3-drug protocol produced in Adbur Rahman v.
Parker – Chancery Court proceedings

482.

6/25/2018 Plaintiffs' Motion and Memorandum of Law Regarding
Defendants New Unwritten Protocol Using Compounded High-Risk Sterile
Injectables filed in Adbur Rahman v. Parker – Chancery Court proceedings

483.

Draft of Defendants Answer to the Amended Petition for Declaratory
Judgment in Adbur Rahman v. Parker – Chancery Court proceedings

484.

Drafts of language for request for admissions in Adbur Rahman v. Parker –
Chancery Court proceedings

485.

6/2/2018 Email, Subject Fw: Plaintiffs Motion to Compel Deposition
Testimony re Adbur Rahman v. Parker – Chancery Court proceedings

486.

5/29/2018 Defendants' Statement of Undisputed Material Facts in Support
of Motion for Summary Judgment in Adbur Rahman v. Parker – Chancery
Court proceedings

487.

5/29/2018 Defendants' Memorandum of Law in Support of Motion for
Summary Judgment in Adbur Rahman v. Parker – Chancery Court
proceedings

488.

Draft of Defendants' Answer to Amended Complaint with redlines in
Adbur Rahman v. Parker – Chancery Court proceedings

489.

3/29/2018 Defendants' Motion to Compel Complaint for Declaratory
Judgment in Adbur Rahman v. Parker – Chancery Court proceedings

490.

3/29/2018 Memorandum of Law in Support of Motion to Dismiss
Complaint for Declaratory Judgment in Adbur Rahman v. Parker –
Chancery Court proceedings

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491.

6/21/2018 Deposition transcript of Debbie Inglis in Adbur Rahman v.
Parker – Chancery Court proceedings

492.

2/20/2018 Complaint for Declaratory Judgment in Adbur Rahman v.
Parker – Chancery Court proceedings

493.

5/8/2018 Defendants' Answer to Amended Complaint in Adbur Rahman v.
Parker – Chancery Court proceedings

494.

Draft of proposed answers to Plaintiffs' amended complaint in Adbur
Rahman v. Parker – Chancery Court proceedings
Amended Complaint for Declaratory Judgment in Adbur Rahman v. Parker
– Chancery Court proceedings

495.

496.

6/13/2018 Memorandum and Orders on: (1) Plaintiffs' Motion to Compel;
(2) Plaintiffs' Notice to Extend Summary Judgment Response time; (3)
Altering and Amending 6/12/2018 Memorandum and Orders; and (4)
6/20/2018 Telephone Conference in Adbur Rahman v. Parker – Chancery
Court proceedings

497.

7/17/2018 Memorandum and Order Regulating (Pursuant to Tenn. Code
Ann. § 10-7-504(h)) Plaintiffs' Offer of Proof in Adbur Rahman v. Parker
– Chancery Court proceedings

498.

7/26/2018 Order Dismissing With Prejudice Plaintiffs' Challenge to
Tennessee Lethal Injection Protocol and Memorandum of Findings of Fact
and Conclusions of Law in Adbur Rahman v. Parker – Chancery Court
proceedings

499.

5/14/2018 Issued Subpoenas to take the depositions of Debbie Inglis and
[Drug Procurer] in Adbur Rahman v. Parker – Chancery Court proceedings

500.

USP 38 - Compounding for Animal Patients produced in Adbur Rahman v.
Parker – Chancery Court proceedings

501.

January 2018 FDA Compounding Guidance - Compounded Drug Products
That are Essentially Copies of a Commercially Available Drug Product
Under Section 503A of the Federal Food, Drug, and Cosmetic Act
produced in Adbur Rahman v. Parker – Chancery Court proceedings

502.

6/25/2018 Email re search to procure Pentobarbital and April 2017 text
messages re acquiring lethal drugs produced in Adbur Rahman v. Parker –
Chancery Court proceedings

BU TLE R I SNOW
503.

Redacted training rosters for electrocution, lethal injection, Practice,
protocol review/training and training materials produced in in Adbur
Rahman v. Parker – Chancery Court proceedings

504.

Redacted IV training results and certificates of completion, redacted
training rosters for execution, protocol review/training, Death Watch,
Practice, Training, electrocution, lethal injection and training materials
produced in in Adbur Rahman v. Parker – Chancery Court proceedings

505.

7/30/2018 filed Plaintiffs Notice of Appeal in in Adbur Rahman v. Parker
– Chancery Court proceedings

506.

7/30/2018 Motion to Vacate Execution Date for Billy Ray Irick

507.

8/6/2018 Order Denying the Motion to Vacate Execution Date for Billy
Ray Irick

508.

8/6/2018 Dissenting Order to majority's opinion

509.

7/30/2018 Motion to Proceed In Forma Pauperis

510.

Picture of thermometer reading in King v. Parker – Middle District of
Tennessee proceedings
6/24/2019 email from Scott Sutherland to Inglis and [Drug Procurer]
enclosing the Amended Complaint and requesting information in King v.
Parker – Middle District of Tennessee proceedings

511.

512.

Draft of a declaration from TDOC Employee in King v. Parker – Middle
District of Tennessee proceedings

513.

Declaration from President of Pharmacy Z signed 7/29/2019 in King v.
Parker – Middle District of Tennessee proceedings

514.

Draft of Declaration from President of Pharmacy Z in King v. Parker –
Middle District of Tennessee proceedings

515.

Declaration from RMSI Officer signed 7/30/2019 in King v. Parker –
Middle District of Tennessee proceedings

516.

Draft of Declaration from RMSI Officer in King v. Parker – Middle
District of Tennessee proceedings

517.

Draft of Declaration from RMSI Mental Health Professional in in King v.
Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
518.

Draft of Declaration from RMSI Employee in King v. Parker – Middle
District of Tennessee proceedings

519.

Draft of Tony Parker's Answer to Amended Complaint in King v. Parker –
Middle District of Tennessee proceedings

520.

Draft of Tony May's Answer to Complaint with comments from [Drug
Procurer] in King v. Parker – Middle District of Tennessee proceedings

521.

Declaration from RMSI Mental Health Professional signed 7/29/2019 in
King v. Parker – Middle District of Tennessee proceedings

522.

9/7/2017 emails regarding procuring lethal drugs, possible insufficiency of
Midazolam as an analgesic produced in King v. Parker – Middle District of
Tennessee proceedings

523.

Redacted handwritten notes re procuring Pentobarbital in King v. Parker –
Middle District of Tennessee proceedings

524.

8/13/2017 TDOC Lethal Injection Update PowerPoint presentation
advising on the current death row inmates, laws re executions and efforts
made to procure chemical to compound lethal drugs for executions
produced in King v. Parker – Middle District of Tennessee proceedings

525.

Spreadsheet re TDOC employee’s involvement with procuring the lethal
drugs and discoverable records in King v. Parker – Middle District of
Tennessee proceedings

526.

1/25/2019 Amended Complaint for Injunctive Relief in King v. Parker –
Middle District of Tennessee proceedings

527.

7/5/2019 Tony May's Answer to Amended Complaint in King v. Parker –
Middle District of Tennessee proceedings

528.

7/5/2019 Tony Parker's Answer to Amended Complaint in King v. Parker
– Middle District of Tennessee proceedings

529.

2/11/2020 and 8/4/2020 redacted lethal injection chemical ledgers
produced in King v. Parker – Middle District of Tennessee proceedings

530.

12/20/2019, 2/11/2020 and 7/28/2020 redacted Lethal injection chemical
Invoices produced in King v. Parker – Middle District of Tennessee
proceedings

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531.

Redacted lethal drug prescriptions for Irick, Zagorski, Miller, Johnson,
West, Hall, Sutton and Nichols produced in King v. Parker – Middle
District of Tennessee proceedings

532.

1/8/2020 Tony Parker's Response to Plaintiff's 1st Set of Interrogatories in
King v. Parker – Middle District of Tennessee proceedings

533.

Redacted dashboard of invoices and payments to pharmacy for lethal drugs
produced in King v. Parker – Middle District of Tennessee proceedings

534.

Sections of policies and procedures for the Execution team, Victim
Services, Execution Perimeter Security cover page, and Execution Forms
produced in King v. Parker – Middle District of Tennessee proceedings

535.

Lethal injection procedures (page 1-50), rev. 7/5/2018 produced in King v.
Parker – Middle District of Tennessee proceedings

536.

8/19/2020 Defendants' Response to Plaintiff's Request for Production of
Documents in King v. Parker – Middle District of Tennessee proceedings

537.

Draft of information to supplement responses to Interrogatory 8 in King v.
Parker – Middle District of Tennessee proceedings

538.

8/19/2020 Tony Mays' Supplemental Response to Plaintiff's 1st Set of
Interrogatories in King v. Parker – Middle District of Tennessee
proceedings

539.

Draft of information to supplement responses to Interrogatory 8 in King v.
Parker – Middle District of Tennessee proceedings

540.

8/19/2020 Tony Parker's Supplemental Response to Plaintiff's 1st Set of
Interrogatories in King v. Parker – Middle District of Tennessee
proceedings

541.

Redacted lethal drug prescription orders for Irick, Zagorski, Miller,
Johnson, West, Hall, Sutton and Nichols produced in King v. Parker –
Middle District of Tennessee proceedings

542.

Tony Parker's Supplemental Response to Plaintiff's 1st Set of
Interrogatories in King v. Parker – Middle District of Tennessee
proceedings

543.

Tony May's Supplemental Response to Plaintiff's 1st Set of Interrogatories
in King v. Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
544.

Draft of proposed supplemental responses to Interrogatories number 8, 9
and 10 in King v. Parker – Middle District of Tennessee proceedings

545.

Redacted 11/27/2017 executed Pharmacy Services Agreement and
2/20/2018 provider agreement for services rendered by doctor during
execution produced in King v. Parker – Middle District of Tennessee
proceedings

546.

2017 emails re Pentobarbital, new 3-drug protocol including Midazolam,
Vecuronium and Potassium Chloride, handwritten notes re procuring
Pentobarbital and Pentobarbital property information produced in King v.
Parker – Middle District of Tennessee proceedings

547.

Notes providing names of "Individuals Listed Pages 12-29" and "35-38" in
King v. Parker – Middle District of Tennessee proceedings

548.

12/19/2019 Email, Subject RE Question in King v. Parker – Middle
District of Tennessee proceedings

549.

Draft of Tony Parker's Supplemental Response to Plaintiff's 1st Set of
Interrogatories in King v. Parker – Middle District of Tennessee
proceedings

550.

Draft of Tony May's Supplemental Response to Plaintiff's 1st Set of
Interrogatories in King v. Parker – Middle District of Tennessee
proceedings

551.

12/20/2019 Email, Subject TN Invoice 20191220.xlxs produced in King v.
Parker – Middle District of Tennessee proceedings

552.

12/19/2019 Email, Subject FW: Question produced in King v. Parker –
Middle District of Tennessee proceedings

553.

12/9/2019 Email, Subject [EXTERNAL] New Invoice produced in King v.
Parker – Middle District of Tennessee proceedings

554.

12/5/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

555.

11/26/2019 Email, Subject [EXTERNAL] Lab results produced in King v.
Parker – Middle District of Tennessee proceedings

556.

11/21/2019 Email, Subject [EXTERNAL] Alternatives produced in King v.
Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
557.

11/20/2019 Email, Subject [EXTERNAL] see attached produced in King v.
Parker – Middle District of Tennessee proceedings

558.

10/30/2019 Email, Subject [EXTERNAL] RE: API produced in King v.
Parker – Middle District of Tennessee proceedings

559.

9/19/2019 Email, Subject [EXTERNAL] Invoices produced in King v.
Parker – Middle District of Tennessee proceedings

560.

8/15/2019 Email, Subject [EXTERNAL] Scanned from a Xerox
[Pharmacy] Pharmacy.pdf produced in King v. Parker – Middle District of
Tennessee proceedings

561.

8/12/2019 Email, Subject [EXTERNAL] 2019-18034.pdf produced in King
v. Parker – Middle District of Tennessee proceedings

562.

8/12/2019 Email, Subject [EXTERNAL] ETX-190806-0007LabReport.pdf produced in King v. Parker – Middle District of Tennessee
proceedings

563.

8/9/2019 Email, Subject [EXTERNAL] results produced in King v. Parker
– Middle District of Tennessee proceedings

564.

8/8/2019 Email, Subject [EXTERNAL] Suitability Test produced in King
v. Parker – Middle District of Tennessee proceedings

565.

8/8/2019 Email, Subject [EXTERNAL] KCI produced in King v. Parker –
Middle District of Tennessee proceedings

566.

8/8/2019 Email, Subject [EXTERNAL] RE: kcl protocol produced in King
v. Parker – Middle District of Tennessee proceedings

567.

8/7/2019 Email, Subject [EXTERNAL] Invoice produced in King v.
Parker – Middle District of Tennessee proceedings

568.

7/31/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

569.

7/29/2019 Email, Subject [EXTERNAL] RE: Declaration produced in
King v. Parker – Middle District of Tennessee proceedings

570.

7/26/2019 Email, Subject RE: Declaration produced in King v. Parker –
Middle District of Tennessee proceedings

571.

7/24/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
572.

7/10/2019 Email, Subject RX produced in King v. Parker – Middle District
of Tennessee proceedings

573.

7/2/2019 Email, Subject [EXTERNAL] FW: kcl protocol produced in King
v. Parker – Middle District of Tennessee proceedings

574.

6/26/2019 Email, Subject kcl protocol produced in King v. Parker –
Middle District of Tennessee proceedings

575.

6/26/2019 Email, Subject Proposed Alternative produced in King v. Parker
– Middle District of Tennessee proceedings

576.

6/26/2019 Email, Subject [EXTERNAL] http://leucadiapharma.com/anticapital-punishment-statement/ produced in King v. Parker – Middle
District of Tennessee proceedings

577.

6/26/2019 Email, Subject KCI produced in King v. Parker – Middle
District of Tennessee proceedings

578.

6/26/2019 Email, Subject [EXTERNAL] KCI Protocol produced in King v.
Parker – Middle District of Tennessee proceedings

579.

5/13/2019 Email, Subject FW: Midazolam produced in King v. Parker –
Middle District of Tennessee proceedings

580.

5/13/2019 Email, Subject RE: Invoice Check produced in King v. Parker –
Middle District of Tennessee proceedings

581.

5/9/2019 Email, Subject RE: Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

582.

5/9/2019 Email, Subject Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

583.

5/9/2019 Email, Subject report produced in King v. Parker – Middle
District of Tennessee proceedings

584.

4/29/2019 Email, Subject Potency report produced in King v. Parker –
Middle District of Tennessee proceedings

585.

4/2/2019 Email, Subject follow up produced in King v. Parker – Middle
District of Tennessee proceedings

586.

2/26/2019 Email, Subject New invoice produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
587.

2/14/2019 Email, Subject RE: Summary of Invoices produced in King v.
Parker – Middle District of Tennessee proceedings

588.

11/7/2018 Email, Subject RE: Payments [secure email] produced in King v.
Parker – Middle District of Tennessee proceedings

589.

11/6/2018 Email, Subject Open invoices produced in King v. Parker –
Middle District of Tennessee proceedings

590.

11/2/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

591.

10/31/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

592.

10/10/2018 Email, Subject Final Report produced in King v. Parker –
Middle District of Tennessee proceedings

593.

8/27/2018 Email, Subject Our friend Wally produced in King v. Parker –
Middle District of Tennessee proceedings

594.

8/24/2018 Email, Subject Fwd: Tennessee License produced in King v.
Parker – Middle District of Tennessee proceedings

595.

8/23/2018 Email, Subject Fwd: produced in King v. Parker – Middle
District of Tennessee proceedings

596.

8/16/2018 Email, Subject TN 81618 produced in King v. Parker – Middle
District of Tennessee proceedings

597.

8/15/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

598.

8/8/2018 Email, Subject Log produced in King v. Parker – Middle District
of Tennessee proceedings

599.

8/6/2018 Email, Subject USP 71 produced in King v. Parker – Middle
District of Tennessee proceedings

600.

7/25/2018 Email, Subject updated invoice produced in King v. Parker –
Middle District of Tennessee proceedings

601.

7/23/2018 Email, Subject Shipping SOP produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
602.

7/18/2018 Email, Subject RE: sample RX produced in King v. Parker –
Middle District of Tennessee proceedings

603.

7/17/2018 Email, Subject sample RX produced in King v. Parker – Middle
District of Tennessee proceedings

604.

7/16/2018 Email, Subject Protocol produced in King v. Parker – Middle
District of Tennessee proceedings

605.

7/15/2018 Email, Subject Fwd: Certificates produced in King v. Parker –
Middle District of Tennessee proceedings

606.

7/12/2018 Email, Subject Testing report produced in King v. Parker –
Middle District of Tennessee proceedings

607.

7/9/2018 Email, Subject RE: Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

608.

7/9/2018 Email, Subject Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

609.

7/9/2018 Email, Subject {No Subject} produced in King v. Parker –
Middle District of Tennessee proceedings

610.

7/5/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

611.

7/3/2018 Email, Subject FW: ACHC Accreditation Decision_60062
[Pharmacy] Specialty Pharmacy produced in King v. Parker – Middle
District of Tennessee proceedings

612.

6/22/2018 Email, Subject {No Subject} produced in King v. Parker –
Middle District of Tennessee proceedings

613.

6/20/2018 Email, Subject Product Inquiry produced in King v. Parker –
Middle District of Tennessee proceedings

614.

4/5/2018 Email, Subject FW: Invoices produced in King v. Parker –
Middle District of Tennessee proceedings

615.

1/22/2018 Email, Subject List of restricted drugs produced in King v.
Parker – Middle District of Tennessee proceedings

616.

87-page PDF containing duplicate copies of 65 emails above produced in
King v. Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
617.

Draft document providing responses to Interrogatories and Requests for
Production produced in King v. Parker – Middle District of Tennessee
proceedings

618.

Tony Parker's Second Supplemental Response to Plaintiff's 1st Set of
Interrogatories produced in King v. Parker – Middle District of Tennessee
proceedings

619.

2020 - 2021 Unredacted training rosters for strap down electrocution and
lethal injection, electrocution, lethal injection, protocol review and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings

620.

2020-2021 training rosters for strap down electrocution and lethal
injection, electrocution, lethal injection, protocol review and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings

621.

5/7/2021 Email from Robert Mitchell to Inglis and Young re depositions
requested from Plaintiffs and supplementing discovery responses produced
in King v. Parker – Middle District of Tennessee proceedings

622.

7/29/2020 redacted training roster for lethal injection and training materials
produced in King v. Parker – Middle District of Tennessee proceedings

623.

Draft of Tony May's 3rd Supplemental Response to Plaintiff's
Interrogatories produced in King v. Parker – Middle District of Tennessee
proceedings

624.

Redacted compounding formulas for Sodium Hydroxide 1%, Edetate
Disodium 1%, Hydrochloric Acid 1%, Midazolam and Potassium Chloride
produced in King v. Parker – Middle District of Tennessee proceedings

625.

Screen shot of text messages re ordering lethal drugs and expiration date
produced in King v. Parker – Middle District of Tennessee proceedings

626.

Screen shot of text messages re inventory of lethal drugs and expiration
dates produced in King v. Parker – Middle District of Tennessee
proceedings

627.

Screen shot of text messages re trip to Nashville (for deposition) produced
in King v. Parker – Middle District of Tennessee proceedings

628.

Screen shot of text messages re emailed inventories for lethal drugs, status
of ordering Vecuronium and potassium chloride and formulas produced in
King v. Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
629.

Screen shot of text messages re travel to Nashville (for deposition)
produced in King v. Parker – Middle District of Tennessee proceedings

630.

Screen shot of text messages re lethal drug and timeframe for its proper use
produced in King v. Parker – Middle District of Tennessee proceedings

631.

Screen shot of text messages re pick up from airport produced in King v.
Parker – Middle District of Tennessee proceedings

632.

Screen shot of text messages re temperature for lethal drug produced in
King v. Parker – Middle District of Tennessee proceedings

633.

Screen shot of text messages re status of ordering lethal drugs and order of
vecuronium produced in King v. Parker – Middle District of Tennessee
proceedings

634.

Screen shot of text messages re wanting to discuss latest lawsuit produced
in King v. Parker – Middle District of Tennessee proceedings

635.

Screen shot of text messages re formulas being proprietary and status of
lethal drug orders, potassium chloride has come in, availability of
vecuronium unclear produced in King v. Parker – Middle District of
Tennessee proceedings

636.

Same Text messages all compiled in a pdf (not in chronological order)
produced in King v. Parker – Middle District of Tennessee proceedings

637.

Same Text messages all compiled in a pdf in chronological order produced
in King v. Parker – Middle District of Tennessee proceedings

638.

12/20/2019 Email, Subject [EXTERNAL] New Invoice produced in King
v. Parker – Middle District of Tennessee proceedings

639.

12/5/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

640.

11/26/2019 Email, Subject [EXTERNAL] Lab results produced in King v.
Parker – Middle District of Tennessee proceedings

641.

11/21/2019 Email, Subject [EXTERNAL] Alternatives produced in King v.
Parker – Middle District of Tennessee proceedings

642.

11/20/2019 Email, Subject [EXTERNAL] see attached produced in King v.
Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
643.

10/30/2019 Email, Subject [EXTERNAL] RE: API produced in King v.
Parker – Middle District of Tennessee proceedings

644.

9/19/2019 Email, Subject [EXTERNAL] Invoices produced in King v.
Parker – Middle District of Tennessee proceedings

645.

8/15/2019 Email, Subject [EXTERNAL] Scanned from a Xerox
[Pharmacy] Pharmacy.pdf produced in King v. Parker – Middle District of
Tennessee proceedings

646.

8/12/2019 Email, Subject [EXTERNAL] 2019-18034.pdf produced in King
v. Parker – Middle District of Tennessee proceedings

647.

8/12/2019 Email, Subject [EXTERNAL] ETX-190806-0007LabReport.pdf produced in King v. Parker – Middle District of Tennessee
proceedings

648.

8/9/2019 Email, Subject [EXTERNAL] results produced in King v. Parker
– Middle District of Tennessee proceedings

649.

8/8/2019 Email, Subject [EXTERNAL] Suitability Test produced in King
v. Parker – Middle District of Tennessee proceedings

650.

8/8/2019 Email, Subject [EXTERNAL] KCI produced in King v. Parker –
Middle District of Tennessee proceedings

651.

8/8/2019 Email, Subject [EXTERNAL] RE: kci protocol produced in King
v. Parker – Middle District of Tennessee proceedings

652.

8/7/2019 Email, Subject [EXTERNAL] Invoice produced in King v.
Parker – Middle District of Tennessee proceedings

653.

7/31/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

654.

7/24/2019 Email, Subject [EXTERNAL] Report produced in King v.
Parker – Middle District of Tennessee proceedings

655.

7/10/2019 Email, Subject RX produced in King v. Parker – Middle District
of Tennessee proceedings

656.

7/2/2019 Email, Subject [EXTERNAL] FW: kci protocol produced in King
v. Parker – Middle District of Tennessee proceedings

657.

6/26/2019 Email, Subject kci protocol produced in King v. Parker –
Middle District of Tennessee proceedings

BU T L E R I SNOW
658.

6/26/2019 Email, Subject Proposed Alternative produced in King v. Parker
– Middle District of Tennessee proceedings

659.

6/26/2019 Email, Subject [EXTERNAL] http://leucadiapharma.com/anticapital-punishment-statement/ produced in King v. Parker – Middle
District of Tennessee proceedings

660.

6/26/2019 Email, Subject KCI produced in King v. Parker – Middle
District of Tennessee proceedings

661.

6/26/2019 Email, Subject [EXTERNAL] KCI Protocol produced in King v.
Parker – Middle District of Tennessee proceedings

662.

5/13/2019 Email, Subject FW: Midazolam produced in King v. Parker –
Middle District of Tennessee proceedings

663.

5/13/2019 Email, Subject RE: Invoice Check produced in King v. Parker –
Middle District of Tennessee proceedings

664.

5/9/2019 Email, Subject RE: Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

665.

5/9/2019 Email, Subject Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

666.

5/9/2019 Email, Subject report produced in King v. Parker – Middle
District of Tennessee proceedings

667.

4/29/2019 Email, Subject Potency report produced in King v. Parker –
Middle District of Tennessee proceedings

668.

4/2/2019 Email, Subject follow up produced in King v. Parker – Middle
District of Tennessee proceedings

669.

2/26/2019 Email, Subject New Invoice produced in King v. Parker –
Middle District of Tennessee proceedings

670.

2/14/2019 Email, Subject RE: Summary of Invoices produced in King v.
Parker – Middle District of Tennessee proceedings

671.

11/7/2018 Email, Subject RE: Payments [secure email] produced in King v.
Parker – Middle District of Tennessee proceedings

672.

11/6/2018 Email, Subject Open Invoices produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
673.

11/2/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

674.

10/31/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

675.

10/10/2018 Email, Subject Final Report produced in King v. Parker –
Middle District of Tennessee proceedings

676.

8/16/2018 Email, Subject TN81618 produced in King v. Parker – Middle
District of Tennessee proceedings

677.

8/15/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

678.

8/8/2018 Email, Subject Log produced in King v. Parker – Middle District
of Tennessee proceedings

679.

8/6/2018 Email, Subject USP 71 produced in King v. Parker – Middle
District of Tennessee proceedings

680.

7/25/2018 Email, Subject updated invoice produced in King v. Parker –
Middle District of Tennessee proceedings

681.

7/23/2018 Email, Subject Shipping SOP produced in King v. Parker –
Middle District of Tennessee proceedings

682.

7/18/2018 Email, Subject RE: sample RX produced in King v. Parker –
Middle District of Tennessee proceedings

683.

7/17/2018 Email, Subject sample Rx produced in King v. Parker – Middle
District of Tennessee proceedings

684.

7/16/2018 Email, Subject Protocol produced in King v. Parker – Middle
District of Tennessee proceedings

685.

7/12/2018 Email, Subject Testing report produced in King v. Parker –
Middle District of Tennessee proceedings

686.

7/9/2018 Email, Subject RE: Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

687.

7/9/2018 Email, Subject Invoices produced in King v. Parker – Middle
District of Tennessee proceedings

BU TLE R I SNOW
688.

7/5/2018 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

689.

7/3/2018 Email, Subject FW: ACHC Accreditation Decision_60062
[Pharmacy] Specialty Pharmacy produced in King v. Parker – Middle
District of Tennessee proceedings

690.

6/22/2018 Email, Subject {NO SUBJECT} produced in King v. Parker –
Middle District of Tennessee proceedings

691.

12/5/2017 Email, Subject RE: More Info produced in King v. Parker –
Middle District of Tennessee proceedings

692.

12/4/2017 Email, Subject RE: {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

693.

12/4/2017 Email, Subject RE {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

694.

12/4/2017 Email, Subject Agreement produced in King v. Parker – Middle
District of Tennessee proceedings

695.

11/28/2017 Email, Subject RE {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

696.

11/28/2017 Email, Subject Re: More Info produced in King v. Parker –
Middle District of Tennessee proceedings

697.

11/28/2017 Email, Subject RE: {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

698.

11/28/2017 Email, Subject {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

699.

11/27/2017 Email, Subject Re: Update produced in King v. Parker –
Middle District of Tennessee proceedings

700.

11/15/2017 Email, Subject Agreement produced in King v. Parker –
Middle District of Tennessee proceedings

701.

11/14/2017 Email, Subject Re: Agreement produced in King v. Parker –
Middle District of Tennessee proceedings

702.

11/14/2017 Email, Subject FW: TN drugs produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
703.

11/14/2017 Email, Subject Info produced in King v. Parker – Middle
District of Tennessee proceedings

704.

11/9/2017 Email, Subject RE: DEA License produced in King v. Parker –
Middle District of Tennessee proceedings

705.

11/9/2017 Email, Subject Question produced in King v. Parker – Middle
District of Tennessee proceedings

706.

11/7/2017 Email, Subject Update produced in King v. Parker – Middle
District of Tennessee proceedings

707.

11/1/2017 Email, Subject RE: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings

708.

11/1/2017 Email, Subject More Info produced in King v. Parker – Middle
District of Tennessee proceedings

709.

11/1/2017 Email, Subject Re: Additional Info produced in King v. Parker –
Middle District of Tennessee proceedings

710.

10/31/2017 Email, Subject Invoice produced in King v. Parker – Middle
District of Tennessee proceedings

711.

10/26/2017 Email, Subject RE: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings

712.

10/20/2017 Email, Subject Can you send the inventory and invoice info?
produced in King v. Parker – Middle District of Tennessee proceedings

713.

10/18/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings

714.

10/17/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings

715.

Attachments providing dosing information for lethal drugs, quantities
needed and available and costs produced in King v. Parker – Middle
District of Tennessee proceedings

716.

12/28/2017 Email, Subject Updated Invoice produced in King v. Parker –
Middle District of Tennessee proceedings

717.

12/28/2017 Email, Subject New Invoice produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
718.

12/15/2017 Email, Subject RE: Info produced in King v. Parker – Middle
District of Tennessee proceedings

719.

12/14/2017 Email, Subject RE: Invoice produced in King v. Parker –
Middle District of Tennessee proceedings

720.

12/12/2017 Email, Subject RE: Call produced in King v. Parker – Middle
District of Tennessee proceedings

721.

12/12/2017 Email, Subject RE: Call produced in King v. Parker – Middle
District of Tennessee proceedings

722.

12/11/2017 Email, Subject Re: Status produced in King v. Parker – Middle
District of Tennessee proceedings

723.

12/11/2017 Email, Subject {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

724.

12/11/2017 Email, Subject {Redacted} produced in King v. Parker –
Middle District of Tennessee proceedings

725.

12/11/2017 Email, Subject RE: Question produced in King v. Parker –
Middle District of Tennessee proceedings

726.

12/11/2017 Email, Subject RE: Can you confirm {Redacted} produced in
King v. Parker – Middle District of Tennessee proceedings

727.

12/11/2017 Email, Subject RE: Can you confirm {Redacted} produced in
King v. Parker – Middle District of Tennessee proceedings

728.

12/6/2017 Email, Subject Re: Update produced in King v. Parker – Middle
District of Tennessee proceedings

729.

12/5/2017 Email, Subject RE: More Info produced in King v. Parker –
Middle District of Tennessee proceedings

730.

Redacted 2/11/2020 and 8/4/2020 lethal drugs inventory produced in King
v. Parker – Middle District of Tennessee proceedings

731.

Redacted 12/30/2017 – 11/26/2019 lethal drugs inventory produced in
King v. Parker – Middle District of Tennessee proceedings

732.

Manual for the Glock Transition Course produced in King v. Parker –
Middle District of Tennessee proceedings

BU TLE R I SNOW
733.

Lesson plan for the Glock Transition Course, FY 2017/2018 produced in
King v. Parker – Middle District of Tennessee proceedings

734.

Lesson plan for the Glock Transition Course, FY 2017/2018 produced in
King v. Parker – Middle District of Tennessee proceedings

735.

PowerPoint presentation on the Glock produced in King v. Parker – Middle
District of Tennessee proceedings

736.

PowerPoint presentation on the Glock produced in King v. Parker – Middle
District of Tennessee proceedings

737.

Program Curriculum for Revolver training, 4/23/2019 produced in King v.
Parker – Middle District of Tennessee proceedings

738.

Firearms Skills Sheet for Revolver/Shotgun produced in King v. Parker –
Middle District of Tennessee proceedings

739.

PowerPoint presentation on the Revolver produced in King v. Parker –
Middle District of Tennessee proceedings

740.

PowerPoint on pre-service firearms training program covering policies and
procedures produced in King v. Parker – Middle District of Tennessee
proceedings

741.

Program curriculum for firearms policies and procedures, rev 7/18/2016
produced in King v. Parker – Middle District of Tennessee proceedings

742.

Program curriculum for range familiarization, rev 7/5/2016 produced in
King v. Parker – Middle District of Tennessee proceedings

743.

Unredacted spreadsheet of staff commissioned as personal protection
officers, as of 12/17/2019 produced in King v. Parker – Middle District of
Tennessee proceedings

744.

Unredacted copies of TDOC Annual Weapons Qualification Cards
produced in King v. Parker – Middle District of Tennessee proceedings

745.

TDOC policies and procedures for Standard Firearms Qualification
Training, effective 4/1/2019 produced in King v. Parker – Middle District
of Tennessee proceedings

746.

Midazolam storage and preparation instructions and Potassium Chloride
preparation instructions produced in King v. Parker – Middle District of
Tennessee proceedings

BU TLE R I SNOW
747.

LIC Administration and IV Training and training materials produced in
King v. Parker – Middle District of Tennessee proceedings

748.

2017 redacted rosters for Execution, Death watch, Practice, Protocol
Review, and Training and training materials produced in King v. Parker –
Middle District of Tennessee proceedings

749.

2020 redacted training rosters for Execution, Review of Protocol, Lethal
Injections, Electrocution and training materials produced in King v. Parker
– Middle District of Tennessee proceedings

750.

2019 - 2020 redacted training rosters for Electrocution, Lethal Injection,
Protocol and training materials produced in King v. Parker – Middle
District of Tennessee proceedings

751.

2019 redacted training rosters for protocol, Lethal Injection and Strap
down and training materials produced in King v. Parker – Middle District
of Tennessee proceedings

752.

2019 redacted training rosters for Lethal Injection, Spike with bag and
Establish IV and training materials produced in King v. Parker – Middle
District of Tennessee proceedings

753.

2019 redacted training rosters for lethal injection and training materials
produced in King v. Parker – Middle District of Tennessee proceedings

754.

2018 - 2019 redacted training rosters for lethal injection and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings

755.

9/25/2018 lethal injection training materials produced in King v. Parker –
Middle District of Tennessee proceedings

756.

2018 redacted training rosters for protocol review, lethal injection, LIC
Administration and IV Training and execution and training materials
produced in King v. Parker – Middle District of Tennessee proceedings

757.

Redacted printout of payments made for lethal drugs and supplies to
pharmacy produced in King v. Parker – Middle District of Tennessee
proceedings

758.

Redacted printout of payments made for lethal drugs and supplies to
pharmacy produced in King v. Parker – Middle District of Tennessee
proceedings

BU TLE R I SNOW
759.

Redacted 12/20/2019, 2/11/2020 and 7/28/2020 pharmacy Invoices
produced in King v. Parker – Middle District of Tennessee proceedings

760.

Redacted dashboard printout of payments to pharmacy and redacted
pharmacy Invoices from 10/26/2017, 11/1/2017, 11/27/2017, 12/14/2017,
12/28/2017, 7/5/2018, 7/5/2018, 8/7/2019, 8/7/2019, 8/16/2018,
10/31/2018, 2/26/2019, and 12/6/2019 produced in King v. Parker –
Middle District of Tennessee proceedings

761.

Redacted 12/20/2017 Prescription for Midazolam 800 vials, Vecuronium
Bromide 400 vials and Potassium Chloride 120 vials produced in King v.
Parker – Middle District of Tennessee proceedings

762.

July 2018 redacted training rosters for lethal injection and Protocol review
and training materials produced in King v. Parker – Middle District of
Tennessee proceedings

763.

Redacted 2017 emails re procuring lethal drugs, 2015 and 2017 training
rosters and materials and Execution Procedures for Electrocution, rev
3/13/2017 produced in King v. Parker – Middle District of Tennessee
proceedings

764.

7/10/2018 redacted training roster for execution protocol produced in King
v. Parker – Middle District of Tennessee proceedings

765.

6/13/2018 redacted training roster for lethal injection practice and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings

766.

10/15/2018 Letter to Kelley Henry at the Federal Public Defender's Office
providing 87 pages of records related to the 9/28/2018 request produced in
King v. Parker – Middle District of Tennessee proceedings

767.

Redacted 2018 training rosters for lethal injection and electric chair and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (87 pages)

768.

10/8/2018 Letter to Kelley Henry at the Federal Public Defender's Office
responding to request for records related to the 9/28/2018 request produced
in King v. Parker – Middle District of Tennessee proceedings

769.

9/28/2018 Letter requesting records under the TPRA related to executions
via lethal injection and electrocution produced in King v. Parker – Middle
District of Tennessee proceedings

BU TLE R I SNOW
770.

Redacted 2007 - 2018 testing logs for electric chair and annual
electrocution equipment inspection letters produced in King v. Parker –
Middle District of Tennessee proceedings (16 pages)

771.

Redacted 2018 training rosters for electrocution practice, electrocution
protocol review, lethal injection protocol, lethal injection practice and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (106 pages)

772.

10/18/2018 Letter from Kelley Henry at the Federal Public Defender's
Office requesting records under the TPRA related to executions via lethal
injection and electrocution and 10/29/2018 Letter providing records in
response produced in King v. Parker – Middle District of Tennessee
proceedings

773.

Redacted emails, Victim forms and letters re attendance at execution,
Outlook notifications for inmate meetings, Electrocution Chronological
Execution Report, TDOC Incident Report and dashboard printouts,
Offender Attributes printout, Personal Property Inventory, Summary of
Death report, Execution day planning docs, Zagorski's Telephone Call Log,
Death Row Offender Info, Tool Inventory and checks, Key Log, PostInspection Form and Tool Control Form produced in King v. Parker –
Middle District of Tennessee proceedings (137 pages)

774.

Redacted Emails, Victim forms and letters re attendance at execution,
Outlook notifications for inmate meetings, Electrocution Chronological
Execution Report, TDOC Incident Report and dashboard printouts,
Offender Attributes printout, Personal Property Inventory, Summary of
Death report, Execution day planning docs, Zagorski's Telephone Call Log,
Death Row Offender Info, Tool Inventory and checks, Key Log, PostInspection Form and Tool Control Form produced in King v. Parker –
Middle District of Tennessee proceedings (121 pages)

775.

Redacted emails, Victim forms and letters re attendance at execution,
Media info and forms for attendance at execution, filings and orders,
Zagorski execution elections, execution notification drafts and final copies
produced in King v. Parker – Middle District of Tennessee proceedings
(207 pages)

776.

Emails, Victim forms and letters re attendance at execution, Media info
and forms for attendance at execution, filings and orders, Zagorski
execution elections, execution notification drafts and final copies produced
in King v. Parker – Middle District of Tennessee proceedings

777.

Emails, execution attendance letters, media attendance and applications,
Zagorski's execution election letter and affidavit to have counsel at

BU TLE R I SNOW
execution, letters from Zagorski's counsel, records re preparation for
execution, Victim Services letters, Outlook meeting records for visits,
Electrocution chronological report records, TDOC Incident Report,
Discipline records, Memo re last meal, offender info, personal property
inventory, Offender information, tool inventory and tool check record
produced in King v. Parker – Middle District of Tennessee proceedings
778.

Redacted training rosters for electrocution practice and lethal injection, and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (32 pages)

779.

11/9/2018 Letter from Jessica Johnson, investigator in the Federal
Defender Services requesting records related to Zagorski's 11/1/2018
execution and records related to drugs intended for use in David Earl
Miller's execution on 12/6/2018 produced in King v. Parker – Middle
District of Tennessee proceedings

780.

Redacted Death Watch logs for Zagorski and redacted Record of staff
visits produced in King v. Parker – Middle District of Tennessee
proceedings (37 pages)

781.

Death Watch logs for Zagorski and Record of Staff Visits for use in King v.
Parker – Middle District of Tennessee proceedings

782.

Redacted Death Watch logs for Zagorski produced in King v. Parker –
Middle District of Tennessee proceedings (75 pages)

783.

Death Watch logs for Zagorski produced in King v. Parker – Middle
District of Tennessee proceedings

784.

11/14/2018 Letter responding to request advising records will be compiled
produced in King v. Parker – Middle District of Tennessee proceedings

785.

11/27/2018 Letter advising that requested records are ready and the cost for
same produced in King v. Parker – Middle District of Tennessee
proceedings

786.

11/7/2017 Email, Subject produced in King v. Parker – Middle District of
Tennessee proceedings

787.

11/28/2017 Email, Subject [Pharmacy] Pharmacy produced in King v.
Parker – Middle District of Tennessee proceedings

788.

11/28/2017 Email, Subject Registering to do business with TN produced in
King v. Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
789.

11/27/2017 Email, Subject Re: Update produced in King v. Parker –
Middle District of Tennessee proceedings

790.

11/27/2017 Email, Subject RE: Update produced in King v. Parker –
Middle District of Tennessee proceedings

791.

11/28/2017 Email, Subject Re: [Pharmacy] Pharmacy produced in King v.
Parker – Middle District of Tennessee proceedings

792.

12/4/2017 Email, Subject Re: [Pharmacy] Pharmacy produced in King v.
Parker – Middle District of Tennessee proceedings
11/28/2017 Email, Subject RE: Registering to do business with TN
produced in King v. Parker – Middle District of Tennessee proceedings

793.
11/28/2017 Email, Subject RE: Registering to do business with TN
produced in King v. Parker – Middle District of Tennessee proceedings
794.
10/18/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings
795.
10/17/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings
796.
10/17/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings
797.
10/18/2017 Email, Subject Re: Question produced in King v. Parker –
Middle District of Tennessee proceedings
798.
11/28/2017 Email, Subject Re: More Info produced in King v. Parker –
Middle District of Tennessee proceedings
799.
11/9/2017 Email, Subject RE: DEA License produced in King v. Parker –
Middle District of Tennessee proceedings
800.
11/9/2017 Email, Subject RE: DEA License produced in King v. Parker –
Middle District of Tennessee proceedings
801.
10/18/2017 Email, Subject RE: Applicant for licensure as a [Pharmacist] in
TN produced in King v. Parker – Middle District of Tennessee proceedings
802.
11/14/2017 Email, Subject Re: Agreement produced in King v. Parker –
Middle District of Tennessee proceedings
803.

BU TLE R I SNOW
11/14/2017 Email, Subject RE: Agreement produced in King v. Parker –
Middle District of Tennessee proceedings
804.
10/26/2017 Email, Subject Re: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings
805.
10/27/2017 Email, Subject RE: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings
806.
11/1/2017 Email, Subject RE: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings
807.
11/9/2017 Email, Subject Question produced in King v. Parker – Middle
District of Tennessee proceedings
808.
10/18/2017 Email, Subject Fwd: Question produced in King v. Parker –
Middle District of Tennessee proceedings
809.
11/8/2017 Email, Subject Fwd: DEA License produced in King v. Parker –
Middle District of Tennessee proceedings
810.
11/14/2017 Email, Subject FW: TN drugs produced in King v. Parker –
Middle District of Tennessee proceedings
811.
10/18/2017 Email, Subject Applicant for licensure as a [Pharmacist] in TN
produced in King v. Parker – Middle District of Tennessee proceedings
812.
12/4/2017 Email, Subject Agreement produced in King v. Parker – Middle
District of Tennessee proceedings
813.
10/26/2017 Email, Subject Additional Info produced in King v. Parker –
Middle District of Tennessee proceedings
814.
10/26/2017 Email, Subject Re: Additional Info produced in King v. Parker
– Middle District of Tennessee proceedings
815.
Redacted emails from 1/3/2018 re Pharmacy's Invoices produced in King v.
Parker – Middle District of Tennessee proceedings
816.
Redacted emails from 12/5/2017 – 1/3/2018 re Pharmacy's Invoices,
confidentiality of pharmacy under TCA 10-7-504(h), shipments of drugs,
scheduling a time to talk on the telephone and Pharmacy's Invoices
produced in King v. Parker – Middle District of Tennessee proceedings
817.

BU TLE R I SNOW
2/20/2018 Agreement between TDOC and redacted unknown party,
Emails, Electric chair testing logs and training logs and materials produced
in King v. Parker – Middle District of Tennessee proceedings (61 pages)
818.
6/5/2018 Letter from Kelley Henry requesting records related to
executions, lethal injections and electrocutions produced in King v. Parker
– Middle District of Tennessee proceedings
819.
Unredacted 5/15/2018 and 5/16/2018 Training rosters for Protocol review
and Lethal Injection and training materials for use in the King v. Parker –
Middle District of Tennessee proceedings
820.
6/12/2018 Letter from Debra Inglis responding to 6/5/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings
821.
6/20/2018 Letter from Debra Inglis providing records in response to
6/5/2018 request produced in King v. Parker – Middle District of
Tennessee proceedings
822.
823.

Redacted 5/15/2018 and 5/16/2018 Training rosters for Protocol review
and Lethal Injection and training materials produced in King v. Parker –
Middle District of Tennessee proceedings (13 pages)

824.

Redacted March 2018 Training rosters for Electric chair, Death Watch,
Lethal Injection, and Protocol Review and training materials produced in
King v. Parker – Middle District of Tennessee proceedings (21 pages)

825.

6/8/2018 Letter from Debra Inglis enclosing records in response to
2/2/2018, 3/7/2018, 4/7/2018 and 5/4/2018 requests, Redacted Agreement
between TDOC and medical provider, March 2016 - August 2018 Electric
chair testing logs, 2018 redacted training rosters and training materials
produced in King v. Parker – Middle District of Tennessee proceedings (93
pages)

826.

4/2/2018 Letter from Debra Inglis providing records in response to requests
on 2/2/2018 and 3/7/2018 produced in King v. Parker – Middle District of
Tennessee proceedings

827.

Redacted Billy Ray Irick Affidavit Concerning Method of Execution and
Affidavit to Select Defense Counsel Witness to Execution and redacted
July 2018 Training rosters for electrocution and lethal injection and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (21 pages)

BU TLE R I SNOW
828.

Billy Ray Irick Affidavit Concerning Method of Execution and Affidavit to
Select Defense Counsel Witness to Execution and unredacted July 2018
Training rosters for electrocution and lethal injection and training materials
produced in King v. Parker – Middle District of Tennessee proceedings

829.

7/10/2018 Letter from Debra Inglis enclosing records in response to
7/3/2018 request for records produced in King v. Parker – Middle District
of Tennessee proceedings (22 pages)

830.

7/3/2018 Letter from Kelley Henry requesting records related to lethal
injection and electrocution produced in King v. Parker – Middle District of
Tennessee proceedings

831.

7/30/2018 Letter from Debra Inglis responding to 7/16/2018 request for
records and enclosing TDOC rules and regulations revision chart produced
in King v. Parker – Middle District of Tennessee proceedings (8 pages)

832.

7/16/2018 Letter from Michael Chavis requesting records re TDOC's rules
and regulations and 7/25/2018 Letter from Debra Inglis responding to the
7/16/2018 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

833.

7/16/2018 Letter from Michael Chavis requesting records re TDOC's rules
and regulations produced in King v. Parker – Middle District of Tennessee
proceedings

834.

8/15/2018 Letter from Debra Inglis enclosing records in response to the
7/26/2018 request with redacted records enclosed produced in King v.
Parker – Middle District of Tennessee proceedings (55 pages)

835.

8/15/2018 Payment receipt for records request produced in King v. Parker
– Middle District of Tennessee proceedings

836.

8/6/2018 Letter from Debra Inglis in response to 7/16/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

837.

7/26/2018 Letter from Kelley Henry requesting records re lethal injection,
electrocution and executions produced in King v. Parker – Middle District
of Tennessee proceedings

838.

Redacted July 2018 training rosters for lethal injection, Protocol training,
execution training and training materials produced in King v. Parker –
Middle District of Tennessee proceedings (27 pages)

BU TLE R I SNOW
839.

Unredacted July 2018 training rosters for lethal injection, protocol training,
execution training and training materials produced in King v. Parker –
Middle District of Tennessee proceedings

840.

Unredacted July 2018 training rosters for lethal injection and protocol and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings

841.

Redacted July 2018 training rosters for lethal injection and protocol and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (29 pages)

842.

8/21/2018 Letter from Debra Inglis responding to requests for records on
8/8/2018 and 8/15/2018 produced in King v. Parker – Middle District of
Tennessee proceedings

843.

7/18/2018 Billy Ray Irick Prescription for Midazolam produced in King v.
Parker – Middle District of Tennessee proceedings

844.

TDOC Incident Report re Billy Ray Irick's execution via lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

845.

Death watch logs for Billy Ray Irick produced in King v. Parker – Middle
District of Tennessee proceedings

846.

Court filings and orders re Billy Ray Irick produced in King v. Parker –
Middle District of Tennessee proceedings

847.

Victim Services forms and letters re attending Irick's execution, Media
information and forms for attending Irick's execution and Elections to
attend Irick's execution produced in King v. Parker – Middle District of
Tennessee proceedings

848.

Irick Motion, Emails, Inmate Inquiry, Visitation records and Order
produced in King v. Parker – Middle District of Tennessee proceedings

849.

Irick Execution day logistics records, Irick TDOC Segregation Unit Record
for Death Sentenced Inmates, Death Row Offender Info, Key Log, Post
Inspection Form, Weekly Tool Inventory, Tool Checks and Control forms
produced in King v. Parker – Middle District of Tennessee proceedings

850.

Midazolam storage and preparation instructions and Pharmacy Invoice
information produced in King v. Parker – Middle District of Tennessee
proceedings

BU TLE R I SNOW
851.

Unredacted July and August 2018 Training rosters for Lethal Injection and
training materials for use in King v. Parker – Middle District of Tennessee
proceedings

852.

9/14/2018 Letter from Michael Chavis renewing his previous request for
certain records re Irick's execution produced in King v. Parker – Middle
District of Tennessee proceedings

853.

9/4/2018 Letter from Debra Inglis responding to 8/15/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

854.

8/15/2018 Letter from Michael Chavis requesting certain records re Irick's
execution produced in King v. Parker – Middle District of Tennessee
proceedings

855.

9/11/2018 Draft letter from Debra Inglis providing records in response to
8/15/2018 request produced in King v. Parker – Middle District of
Tennessee proceedings

856.

9/21/2018 Draft letter from Debra Inglis responding to 9/14/2018 and
8/15/2018 requests for records produced in King v. Parker – Middle
District of Tennessee proceedings

857.

Victim Notification Services - What to Expect on Execution Day produced
in King v. Parker – Middle District of Tennessee proceedings (7 pages)

858.

9/24/2018 Letter from Debra Inglis enclosing records in response to
8/15/2018 and 9/14/2018 requests for records and enclosing Victim
Notification Services brochure re What to Expect on Execution Day
produced in King v. Parker – Middle District of Tennessee proceedings

859.

TDOC Critical Incident Stress Management info for family members and
friends after an execution produced in King v. Parker – Middle District of
Tennessee proceedings

860.

9/11/2018 Letter from Debra Inglis providing records in response to
8/15/2018 request produced in King v. Parker – Middle District of
Tennessee proceedings

861.

Redacted June and July 2018 training rosters for lethal injection practice,
protocol training and review, electrocution and execution training and
training materials and Irick's Affidavits Concerning Method of Execution
and selection of attorney to witness the execution produced in King v.
Parker – Middle District of Tennessee proceedings (141 pages)

BU TLE R I SNOW
862.

9/4/2018 Letter from Debra Inglis providing records in response to requests
on 8/8/2018 and 8/15/2018 produced in King v. Parker – Middle District of
Tennessee proceedings

863.

8/8/2018 Letter from Paul Bottei requesting records re lethal drugs for
Irick's execution produced in King v. Parker – Middle District of
Tennessee proceedings

864.

Redacted Media Info and forms for Irick's execution and elections to
witness Irick's execution produced in King v. Parker – Middle District of
Tennessee proceedings (41 pages)

865.

Redacted July and August 2018 training rosters for lethal injection and
training materials, Irick Death Watch logs, Irick Midazolam prescription,
Midazolam storage and preparation instructions, TDOC Incident Report,
Affidavits re selection of defense counsel to witness execution and method
of execution, notification letter re execution, Irick's Day of Execution Lethal Injection Execution Recorder Checklist, Chemical preparation
records and Victim Services forms and letters re attendance at execution
produced in King v. Parker – Middle District of Tennessee proceedings
(150 pages)

866.

Execution documents for Billy Ray Irick produced in King v. Parker –
Middle District of Tennessee proceedings (17 pages)

867.

Redacted 9/18/2019 training rosters for Lethal injection practice and
training materials produced in King v. Parker – Middle District of
Tennessee proceedings (14 pages)

868.

10/15/2019 Letter from Debra Inglis providing records in response to
9/24/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

869.

9/24/2019 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

870.

11/6/2019 Letter from Evelyn Caicedo requesting records re Execution
Procedures for Electrocution produced in King v. Parker – Middle District
of Tennessee proceedings

871.

11/13/2019 Letter from [Drug Procurer] responding to 11/6/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

BU TLE R I SNOW
872.

11/22/2019 Letter from [Drug Procurer] providing records in response to
11/6/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

873.

Execution Procedures for Electrocution, rev. 3/13/2017 produced in King v.
Parker – Middle District of Tennessee proceedings (88 pages)

874.

Lethal Injection Execution Manual Execution Procedures for Lethal
Injection, rev 7/5/2018 produced in King v. Parker – Middle District of
Tennessee proceedings (99 pages)

875.

1/2/2019 Letter from Jessica Johnson requesting records re procurement of
lethal injection chemicals produced in King v. Parker – Middle District of
Tennessee proceedings

876.

1/3/2019 Letter from Debra Inglis responding to 1/2/2019 request produced
in King v. Parker – Middle District of Tennessee proceedings

877.

1/18/2018 Letter from Debra Inglis providing records in response to
1/2/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings (29 pages)

878.

Records re Invoices and payments to [Pharmacy], [Pharmacy] Invoices,
7/1/2018 Letter re approval of vouchers for payment with redacted info
produced in King v. Parker – Middle District of Tennessee proceedings

879.

1/2/2019 Email from Neysa Taylor to Debbie Inglis enclosing a 1/2/2019
public records request addressed to the Tennessee Department of Finance
from Jessica Johnson produced in King v. Parker – Middle District of
Tennessee proceedings

880.

2/15/2019 draft letter from Debra Inglis providing records in response to
2/11/2019 and 10/31/2018 request produced in King v. Parker – Middle
District of Tennessee proceedings

881.

2/5/2019 Letter from Debra Inglis responding to 1/2/2019 and 1/29/2019
requests sent to the Department of Health and responding to 1/31/2019
request for additional information produced in King v. Parker – Middle
District of Tennessee proceedings

882.

2/8/2019 Letter from Debra Inglis providing a response to the 1/8/2019
request and enclosing redacted [Pharmacy] Invoices and TDOC payment
records produced in King v. Parker – Middle District of Tennessee
proceedings (6 pages)

BU TLE R I SNOW
883.

1/3/2019 Letter from Debra Inglis responding to the 1/2/2019 request
addressed to the Tennessee Department of Finance produced in King v.
Parker – Middle District of Tennessee proceedings

884.

1/10/2019 Letter from Debra Inglis responding to the 1/2/2019 request
addressed to the Tennessee Department of Finance produced in King v.
Parker – Middle District of Tennessee proceedings

885.

Redacted TDOC records re [Pharmacy] Invoices and payments produced in
King v. Parker – Middle District of Tennessee proceedings (3 pages)

886.

2/22/2019 Letter from Debra Inglis responding to 2/11/2019 Letter and
enclosing Redacted TDOC records re [Pharmacy] Invoices and payments
produced in King v. Parker – Middle District of Tennessee proceedings (4
pages)

887.

1/2/2019 Letter from Jessica Johnson to TDOC requesting records re
procurement of lethal injection chemicals produced in King v. Parker –
Middle District of Tennessee proceedings

888.

1/2/2019 Letter from Jessica Johnson to Tennessee Department of Finance
requesting records re procurement of lethal injection chemicals produced in
King v. Parker – Middle District of Tennessee proceedings

889.

2/11/2019 Letter from Jessica Johnson following up to original request on
1/2/2019 produced in King v. Parker – Middle District of Tennessee
proceedings

890.

Redacted Death Watch logs for Stephen West produced in King v. Parker –
Middle District of Tennessee proceedings (28 pages)

891.

Redacted August 2019 - November 2019 training rosters for Strap Down
training, Lethal Injection, Electrocution, Protocol Review, and training
materials, Media info and forms re attendance at execution, Outlook
notifications for meetings, Victim Services notices and letters, elections to
attend execution, TDOC Incident Report of West's death, Day of Execution
- Electrocution Execution Recorder Checklist, Record of Staff Visits and
Death Watch Logs produced in King v. Parker – Middle District of
Tennessee proceedings (147 pages)

892.

Redacted August 2019 Training Rosters for Lethal Injection and Electric
Chair and training materials produced in King v. Parker – Middle District
of Tennessee proceedings (33 pages)

893.

Redacted May 2019 - August 2019 Training Rosters for Electrocution,
Lethal Injection and Spike IV Bag and Establish IV and training materials

BU TLE R I SNOW
produced in King v. Parker – Middle District of Tennessee proceedings
(139 pages)
894.

11/14/2019 Letter from Debra Inglis responding to 11/14/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

895.

12/17/2019 Letter from Debra Inglis providing records in response to
11/14/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

896.

Redacted TDOC Incident Report re death of West, Day of Execution Electrocution Execution Recorder Checklist and Record of Staff Visits
produced in King v. Parker – Middle District of Tennessee proceedings (22
pages)

897.

12/9/2019 Letter from Debra Inglis responding to 12/9/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

898.

11/14/2019 Letter from Jessica Johnson requesting records re lethal
injection records and West electrocution records produced in King v.
Parker – Middle District of Tennessee proceedings

899.

Redacted 10/29/2018 Training rosters for Electrocution practice and Lethal
Injection and training materials produced in King v. Parker – Middle
District of Tennessee proceedings (32 pages)

900.

1/31/2019 Letter from Debra Inglis responding to 1/22/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

901.

Redacted October 2018 - January 2019 Training rosters for Electrocution
practice, Lethal Injection and Electric Chair and training materials and
Electric Chair testing logs, [Pharmacy] invoice and payment info produced
in King v. Parker – Middle District of Tennessee proceedings (128 pages)

902.

Redacted December 2017 - 2018 lethal drug inventory logs produced in
King v. Parker – Middle District of Tennessee proceedings (3 pages)

903.

1/22/2019 Letter from Kelley Henry requesting records re lethal injection,
electrocution and executions and 1/25/2019 Letter from Debra Inglis
responding to 1/22/2019 request produced in King v. Parker – Middle
District of Tennessee proceedings

904.

Redacted Electric Chair testing logs for 2018, Unredacted November 2018
- January 2019 training rosters for Electric Chair, Lethal Injection and
Electrocution and training materials produced in King v. Parker – Middle
District of Tennessee proceedings

BU TLE R I SNOW
905.

2/13/2019 Email from [Drug Procurer] to [Drug Procurer] enclosing
unredacted 12/30/2017 – 11/20/2018 lethal drug inventories produced in
King v. Parker – Middle District of Tennessee proceedings

906.

2/19/2019 Letter from Debra Inglis in response to 2/8/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

907.

Record of staff visits, Zagorski's Medical Examiner's Report and Labs,
Irick's Medical Examiner's Report and Labs, TDOC Incident Report for
Miller's death, Email requesting Miller's autopsy report, Miller's TDOC
Summary of Death, Letter Requesting Miller's autopsy report, and Media
Info and selection records produced in King v. Parker – Middle District of
Tennessee proceedings (130 pages)

908.

Redacted Death Watch logs for Miller produced in King v. Parker –
Middle District of Tennessee proceedings (42 pages)

909.

Redacted Media Info and selection records, Miller execution attendance
elections, Miller's affidavit re selection of attorney at execution, letters
from Miller's attorney, Emails, Notification letter re execution, Outlook
notifications for visits, Offender info, Miller TDOC Incident Reports re
Miller's execution, Miller's Day of Execution - Electrocution Execution
Recorder Checklist, Inmate Inquiry, Miller Summary of Death, TDOC
Health Services Morbidity and Mortality Summary, Miller filings and
Orders, Visitor and visitation records, TDOC Incident record, 12/6/2018
handwritten note re staying Miller's execution, Miller Incident reports and
USPS Return Receipts produced in King v. Parker – Middle District of
Tennessee proceedings (172 pages)

910.

Miller Incident report, USPS Return Receipts, Redacted Record of Staff
Visits and redacted lethal drug inventories from September 2018 December 2018 produced in King v. Parker – Middle District of Tennessee
proceedings (37 pages)

911.

Media info and selections to attend execution, Miller Death Watch logs,
Victim Services letters and elections to attend execution, Miller's Affidavit
re selecting counsel to attend execution, Outlook notifications of visits,
Memo re Miller's legal visits, Emails, Offender Info, TDOC Incident
Reports, Day of Execution - Electrocution Execution Recorder Checklist,
Inmate Inquiry, Orders and filings and Miller visitor and visitation records
produced in King v. Parker – Middle District of Tennessee proceedings
(192 pages)

100

BU TLE R I SNOW
912.

2/8/2019 Email from Debbie Inglis to [Drug Procurer] forwarding an email
from Kelley Henry clarifying records requested produced in King v. Parker
– Middle District of Tennessee proceedings

913.

2/19/2019 Email from [Drug Procurer] to Janet Santana regarding records
requested produced in King v. Parker – Middle District of Tennessee
proceedings

914.

Unredacted Record of staff visits, Zagorski's Medical Examiner's Report
and Labs, Irick's Medical Examiner's Report and Labs, TDOC Incident
Report for Miller's death, Email requesting Miller's autopsy report, Miller's
TDOC Summary of Death, Letter Requesting Miller's autopsy report, and
Media Info and selection records produced in King v. Parker – Middle
District of Tennessee proceedings

915.

Unredacted Death Watch logs for Miller produced in King v. Parker –
Middle District of Tennessee proceedings

916.

Unredacted Media Info and selection records, Miller execution attendance
elections, Miller's affidavit re selection of attorney at execution, letters
from Miller's attorney, Emails, Notification letter re execution, Outlook
notifications for visits, Offender info, Miller TDOC Incident Reports re
Miller's execution, Miller's Day of Execution - Electrocution Execution
Recorder Checklist, Inmate Inquiry, Miller Summary of Death, TDOC
Health Services Morbidity and Mortality Summary, Miller filings and
Orders, Visitor and visitation records, TDOC Incident record, 12/6/2018
handwritten note re staying Miller's execution, Miller Incident reports and
USPS Return Receipts produced in King v. Parker – Middle District of
Tennessee proceedings

917.

4/15/2019 Letter from Debra Inglis responding to 3/28/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

918.

Redacted electric chair testing log, Redacted February 2019 - March 2019
Training Rosters for Injection and Electrocution and training materials
produced in King v. Parker – Middle District of Tennessee proceedings (48
pages)

919.

Unredacted electric chair testing log, Unredacted February 2019 - March
2019 Training Rosters for Injection and Electrocution and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings

920.

4/1/2019 Letter from Debra Inglis responding to 3/28/2019 request
produced in King v. Parker – Middle District of Tennessee proceedings

101

BU TLE R I SNOW
921.

3/28/2018 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

922.

Redacted April 2019 - May 2019 Training Rosters for Lethal Injection,
Electrocution, and training materials produced in King v. Parker – Middle
District of Tennessee proceedings

923.

2/26/2019 [Pharmacy] Invoice for Bacteriostatic water, Sodium Chloride
and Lactated Ringers produced in King v. Parker – Middle District of
Tennessee proceedings

924.

Redacted November 2018 - March 2019 Training Rosters for
Electrocution, Lethal Injection, 2018 - 2019 electric chair testing logs,
2/26/2019 [Pharmacy] Invoice and May 9, 2019 lethal drug inventory
produced in King v. Parker – Middle District of Tennessee proceedings

925.

5/8/2019 Letter from Debra Inglis responding to 5/6/2019 request produced
in King v. Parker – Middle District of Tennessee proceedings

926.

5/23/2019 Letter from Debra Inglis responding to 5/6/2019 request with
cost produced in King v. Parker – Middle District of Tennessee
proceedings

927.

5/6/2019 Letter from Jessica Johnson requesting records re lethal injection
and electrocution produced in King v. Parker – Middle District of
Tennessee proceedings

928.

6/14/2019 Letter from Debra Inglis responding 6/10/2019 request and
enclosing Dec 2017 - Nov 2018 redacted lethal drugs inventory produced
in King v. Parker – Middle District of Tennessee proceedings (9 pages)

929.

Redacted Dec 2017 - Nov 2018 lethal drugs inventory produced in King v.
Parker – Middle District of Tennessee proceedings (7 pages)

930.

Unredacted Dec 2017 - Nov 2018 lethal drugs inventory for use in King v.
Parker – Middle District of Tennessee proceedings

931.

6/10/2019 Letter from Jessica Johnson requesting records re lethal drug
inventories produced in King v. Parker – Middle District of Tennessee
proceedings

932.

6/5/2019 Email from [Drug Procurer] to Janet Santana responding to
5/20/2019 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

102

BU TLE R I SNOW
933.

Redacted Record of Staff Visits, Donnie Johnson Day of Execution Lethal Injection Execution Recorder Checklist, Chemical prep sheets and
TDOC Incident Report for Charles Walton Wright produced in King v.
Parker – Middle District of Tennessee proceedings (18 pages)

934.

Inmate card, Media Info and selections for execution, Elections to attend
execution, Victim Services forms and letters, Johnson's Affidavit to Select
Defense Counsel Witness to Execution, Emails, Method of execution
notification letter, Affidavit Concerning Method of Execution, Outlook
notifications for meetings, TDOC Offender Info, TDOC Incident Reports,
Visitor and Visitation records, Letters to Gov. Lee re clemency, Death
Watch logs, May 9, 2019 Inventory of Midazolam and Record of Staff
Visits produced in King v. Parker – Middle District of Tennessee
proceedings (188 pages)

935.

5/22/2019 Email from [Drug Procurer] to Debbie Inglis with draft response
to Kelly Henry's 5/20/2019 request for records produced in King v. Parker
– Middle District of Tennessee proceedings

936.

Unredacted 5/9/2019 lethal drug inventory for Midazolam for use in King
v. Parker – Middle District of Tennessee proceedings

937.

6/5/2019 Letter from Debra Inglis to Kelley Henry responding to
5/20/2019 request with cost produced in King v. Parker – Middle District
of Tennessee proceedings

938.

4/24/2019 Email from Melissa Hood to Debbie Inglis enclosing 4/16/2019
Letter from the Eleos Institute re upgrading state's electric chair produced
in King v. Parker – Middle District of Tennessee proceedings

939.

Redacted Inmate card, Media Info and selections for execution, Elections
to attend execution, Victim Services forms and letters, Johnson's Affidavit
to Select Defense Counsel Witness to Execution, Emails, Method of
execution notification letter, Affidavit Concerning Method of Execution,
Outlook notifications for meetings, TDOC Offender Info, TDOC Incident
Reports, Visitor and Visitation records, Execution day planning records,
Phone call logs and Letters to Gov. Lee re clemency produced in King v.
Parker – Middle District of Tennessee proceedings (182 pages)

940.

Unredacted Inmate card, Media Info and selections for execution, Elections
to attend execution, Victim Services forms and letters, Johnson's Affidavit
to Select Defense Counsel Witness to Execution, Emails, Method of
execution notification letter, Affidavit Concerning Method of Execution,
Outlook notifications for meetings, TDOC Offender Info, TDOC Incident
Reports, Visitor and Visitation records, Execution day planning records,

103

BU TLE R I SNOW
Phone call logs and Letters to Gov. Lee re clemency for use in King v.
Parker – Middle District of Tennessee proceedings
941.

Redacted Johnson Death Watch logs produced in King v. Parker – Middle
District of Tennessee proceedings (48 pages)

942.

Unredacted Johnson Death Watch logs for use in King v. Parker – Middle
District of Tennessee proceedings

943.

Redacted TDOC internal record of Johnson's execution, Summary of
Death, Execution day planning records, record of staff visits, Johnson Day
of Execution - Lethal Injection Execution Recorder Checklist, Chemical
prep records and TDOC Incident Report for Charles Walton Wright
produced in King v. Parker – Middle District of Tennessee proceedings (35
pages)

944.

Unredacted TDOC internal record of Johnson's execution, Summary of
Death, Execution day planning records, record of staff visits, Johnson Day
of Execution - Lethal Injection Execution Recorder Checklist, Chemical
prep records and TDOC Incident Report for Charles Walton Wright for use
in King v. Parker – Middle District of Tennessee proceedings

945.

Redacted April 2019 - August 2019 Training rosters for lethal injection,
electrocution, Spike IV Bag and Establish IV, Strap down and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings (325 pages)

946.

Unredacted April 2019 - August 2019 Training rosters for lethal injection,
electrocution, Spike IV Bag and Establish IV, Strap down and training
materials for use in King v. Parker – Middle District of Tennessee
proceedings

947.

8/6/2019 Letter from Debra Inglis responding to 8/1/2019 request produced
in King v. Parker – Middle District of Tennessee proceedings

948.

8/30/2019 Letter from Debra Inglis providing records in response to
8/1/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

949.

8/1/2019 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

950.

11/16/2020 Email from Richard Tennent to [Drug Procurer] enclosing
11/16/2020 request for records re COVID-19 policies and procedures in

104

BU TLE R I SNOW
place at Riverbend produced in King v. Parker – Middle District of
Tennessee proceedings
951.

11/24/2020 Letter from [Drug Procurer] responding to 11/16/2020 request
for records and enclosing TDOC Memos and protocols re COVID-19
produced in King v. Parker – Middle District of Tennessee proceedings

952.

11/16/2020 Letter from Richard Tennent requesting records re COVID-19
policies and procedures in place at Riverbend produced in King v. Parker –
Middle District of Tennessee proceedings

953.

1/15/2020 Email from [Drug Procurer] to Janet Santana responding to
12/13/2019 request for records produced in King v. Parker – Middle
District of Tennessee proceedings

954.

November 2019 - December 2019 redacted training rosters for
electrocution and lethal injection and training materials, redacted emails
from/about [Pharmacy] re invoices, payments, lethal drug shipments,
procuring lethal drugs and lab reports produced in King v. Parker – Middle
District of Tennessee proceedings (67 pages)

955.

October 2019 - November 2019 redacted training rosters for lethal
injection, electrocution and lethal injection protocol reviews, electrocution,
and training materials produced in King v. Parker – Middle District of
Tennessee proceedings (52 pages)

956.

Redacted Record of Staff Visits produced in King v. Parker – Middle
District of Tennessee proceedings (10 pages)

957.

Media Info and selections to view execution of Stephen West, letters re
attendance at execution, Outlook notifications for visitations, West'
Personal Property inventory and Storage Request, Death Watch logs,
TDOC Incident Report and Day of Execution - Electrocution Execution
Recorder Checklist produced in King v. Parker – Middle District of
Tennessee proceedings (120 pages)

958.

12/13/2019 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

959.

12/18/2019 Letter from Debra Inglis responding to request for records on
12/13/2019 produced in King v. Parker – Middle District of Tennessee
proceedings

105

BU TLE R I SNOW
960.

1/31/2020 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

961.

Redacted 12/20/2019 Invoice from [Pharmacy] produced in King v. Parker
– Middle District of Tennessee proceedings

962.

12/20/2019 Invoice from [Pharmacy] for Midazolam and KCI produced in
King v. Parker – Middle District of Tennessee proceedings

963.

Redacted February 2020 Training rosters for Electrocution and training
materials, redacted drug logs and redacted 12/20/2019 Invoice from
[Pharmacy] produced in King v. Parker – Middle District of Tennessee
proceedings (9 pages)

964.

Redacted January 2020 - February 2020 Training rosters for Protocol,
lethal injection, electrocution, and training materials produced in King v.
Parker – Middle District of Tennessee proceedings (116 pages)

965.

2/4/2020 Letter from Debra Inglis responding to 1/31/2020 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

966.

2/24/2020 Letter from Debra Inglis providing records in response to
1/31/2019 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

967.

Unredacted February 2020 - March 2020 Training rosters for electrocution,
lethal injection, Review of Protocol, and training materials and Day of
Execution - Electrocution Execution Recorder Checklist for use in King v.
Parker – Middle District of Tennessee proceedings

968.

3/2/2020 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

969.

Redacted February 2020 - March 2020 Training rosters for electrocution,
review of protocol, lethal injection, and training materials, and redacted
August 2019 - February 2020 drug inventory logs produced in King v.
Parker – Middle District of Tennessee proceedings (21 pages)

970.

3/9/2020 Letter from Debra Inglis responding to 3/2/2020 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

106

BU TLE R I SNOW
971.

3/23/2020 Letter from Debra Inglis providing records in response to
3/2/2020 request produced in King v. Parker – Middle District of
Tennessee proceedings

972.

Redacted August 2019 - February 2020 Electric chair testing logs produced
in King v. Parker – Middle District of Tennessee proceedings

973.

Unredacted August 2019 - February Electric chair testing logs produced in
King v. Parker – Middle District of Tennessee proceedings

974.

6/3/2020 Email from [Drug Procurer] to Debbie Inglis with draft response
to 5/29/2020 request for records produced in King v. Parker – Middle
District of Tennessee proceedings

975.

Redacted 5/28/2020 training roster for Lethal Injections, Aug 2019 - Feb
2020 Electric Chair testing log, 2/11/2020 Lethal drug inventory and
2/11/2020 [Pharmacy] Invoice for KCI and Midazolam produced in King v.
Parker – Middle District of Tennessee proceedings (5 pages)

976.

Redacted January 2020 - March 2020 and May 2020 training rosters for
Protocol, Lethal Injection, Electrocution, Review of Protocol, and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings (144 pages)

977.

5/29/2020 Email from Debbie Inglis to [Drug Procurer] forwarding
5/29/2020 Request for Records re lethal injection and electrocution
produced in King v. Parker – Middle District of Tennessee proceedings

978.

6/8/2020 Letter from Debra Inglis responding to 5/29/2020 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

979.

5/29/2020 Letter from Michael Chavis requesting records re lethal
injection and electrocution produced in King v. Parker – Middle District of
Tennessee proceedings

980.

Redacted June 2020 - July 2020 training rosters for lethal injection,
electrocution and Protocol and training materials produced in King v.
Parker – Middle District of Tennessee proceedings (22 pages)

981.

8/7/2020 Email from Debbie Inglis to [Drug Procurer] re responding to
records request produced in King v. Parker – Middle District of Tennessee
proceedings

982.

Redacted 7/29/2020 training roster for lethal injection and training
materials, 7/28/2020 [Pharmacy] Invoice the annual service fee, lethal

107

BU TLE R I SNOW
drugs and supplies produced in King v. Parker – Middle District of
Tennessee proceedings
983.

8/10/2020 Email from Melissa Hood to [Drug Procurer] encl unredacted
7/29/2020 training roster for lethal injection and training materials for use
in King v. Parker – Middle District of Tennessee proceedings

984.

Unredacted 7/29/2020 training roster for lethal injection and training
materials for use in King v. Parker – Middle District of Tennessee
proceedings (16 pages)

985.

7/29/2020 Letter from Michael Chavis requesting records re lethal
injection, electrocution and execution produced in King v. Parker – Middle
District of Tennessee proceedings

986.

3/14/2022 Draft letter from Debra Inglis to Kelley Henry providing records
in response to 2/11/2022 request produced in King v. Parker – Middle
District of Tennessee proceedings

987.

2/11/2022 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

988.

Redacted Nov 2021 - January 2022 Training rosters for protocol, strap
down, electrocution, and lethal injection, and training materials produced
in King v. Parker – Middle District of Tennessee proceedings (36 pages)

989.

Redacted Nov 2021 - January 2022 Training rosters for protocol, strap
down, electrocution, and lethal injection, and training materials,
11/30/2021 [Pharmacy] Invoice, Lethal drugs inventory log, and November
2021 emails re ordering lethal drugs and status of delivery produced in
King v. Parker – Middle District of Tennessee proceedings (23 pages)

990.

1/3/2022 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

991.

11/30/2021 Redacted [Pharmacy] Invoice for Sodium Chloride and
Vecuronium produced in King v. Parker – Middle District of Tennessee
proceedings

992.

Redacted 12/1/2021 Drug inventory log for Vecuronium Bromide
produced in King v. Parker – Middle District of Tennessee proceedings

993.

Unredacted 12/1/2021 Drug inventory log for Vecuronium Bromide for use
in King v. Parker – Middle District of Tennessee proceedings

108

BU TLE R I SNOW
994.

Draft 1/25/2022 Letter from Debra Inglis to Kelley Henry responding to
1/3/2022 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

995.

Draft 1/31/2022 Letter from Debra Inglis to Kelley Henry providing
records in response to 1/3/2022 request for records produced in King v.
Parker – Middle District of Tennessee proceedings

996.

Redacted Feb 2022 - Mar 2022 training rosters for lethal injection, redacted
email re training requirements for sterile compounding and inventory of
lethal drugs, discovery responses, Midazolam and KCI inventory log,
training rosters, ordering lethal drugs and supplies, shipments of lethal
drugs and supplies, pharmaceutical letters re misuse of products, Redacted
Tennessee Board of Pharmacy license and DEA license, [Pharmacy]
Invoices, Feb 2020 - Dec 2021 lethal drug inventory logs, potassium
chloride and midazolam logs, and Feb 2020 - Oct 2021 Electric chair
testing logs produced in King v. Parker – Middle District of Tennessee
proceedings (61 pages)

997.

Redacted June 2021 - Nov 2021 and Jan 2022 - Feb 2022 training rosters
for Protocol, lethal injection, electrocution, strap down team, and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings (132 pages)

998.

Redacted June 2021 training rosters for electrocution (and page 2 of lethal
injection) and lethal injection training materials produced in King v. Parker
– Middle District of Tennessee proceedings (20 pages)

999.

Redacted July 2020 - June 2021 training rosters for protocol review, lethal
injection, electrocution and lethal injection strap down, electrocution, lethal
injection, electrocution and lethal injection protocol review and training
materials produced in King v. Parker – Middle District of Tennessee
proceedings (139 pages)

1000.

Draft 3/11/2022 Letter from Debra Inglis responding to 3/2/2022 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1001.

Draft March 2022 Letter from Debra Inglis responding to 3/2/2022 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1002.

3/2/2022 Letter from Michael Chavis requesting records re lethal injection,
electrocution, and execution produced in King v. Parker – Middle District
of Tennessee proceedings

109

BU TLE R I SNOW
1003.

April 2021 - February 2022 Redacted Electric Chair Testing Logs
produced in King v. Parker – Middle District of Tennessee proceedings

1004.

3/18/2022 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution produced in King v. Parker – Middle District
of Tennessee proceedings

1005.

Redacted 3/8/2022 training rosters for lethal injection and training
materials, Redacted Sept 2021 - Feb 2022 Electric Chair testing log, and
redacted 3/16/2022 email re an order produced in King v. Parker – Middle
District of Tennessee proceedings (13 pages)

1006.

Draft 3/25/2022 Letter from Debra Inglis responding to 3/18/2022 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1007.

4/26/2022 Email from [Drug Procurer] to [Drug Procurer] attaching picture
of unredacted 4/13/2022 lethal drugs inventory log produced in King v.
Parker – Middle District of Tennessee proceedings

1008.

Unredacted 4/13/2022 lethal drugs inventory log produced in King v.
Parker – Middle District of Tennessee proceedings

1009.

Unredacted 4/21/2022 inventory logs for drugs and supplies in the
refrigerator and cabinet for use in King v. Parker – Middle District of
Tennessee proceedings

1010.

Unredacted 4/21/2022 lethal drugs inventory log for use in King v. Parker
– Middle District of Tennessee proceedings

1011.

Redacted March 2021 - June 2021 training rosters for lethal injection,
protocol, electrocution, and training materials, pharmaceutical letters re
misuse of product, 8/13/2020 Email re suppliers’ inventory of lethal drugs
after compounding and attached logs produced in King v. Parker – Middle
District of Tennessee proceedings (67 pages)

1012.

Redacted Feb 20, 2020 - Jan 26, 2021 electric chair testing logs, Feb 2020 August 2020 lethal drug inventory logs, [Pharmacy] invoices, training
rosters May 2020 - July 2020, Oct 2020 and Dec 2020 - March 2021 for
protocol review, electrocution, Lethal injection, electrocution strap down,
lethal injection strap down, and training materials produced in King v.
Parker – Middle District of Tennessee proceedings (134 pages)

1013.

6/28/2021 Letter from Kelley Henry requesting records re lethal injection,
electrocution and execution and 7/1/2021 Letter from Debra Inglis

110

BU TLE R I SNOW
responding to 6/28/2021 request produced in King v. Parker – Middle
District of Tennessee proceedings
1014.

7/7/2021 Letter from Debra Inglis providing records in response to
6/28/2021 request produced in King v. Parker – Middle District of
Tennessee proceedings

1015.

2/14/2018 RMSI Death Watch Post Orders, Protester sign-in sheet for
David Miller, List of Protesters, surveillance pictures of protesters
produced in King v. Parker – Middle District of Tennessee proceedings (16
pages)

1016.

1/31/2019 Letter from [Drug Procurer] responding 1/1/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

1017.

1/29/2019 email from Korey Cooper to [Drug Procurer] attaching,
2/4/2018 redacted and unredacted RMSI Death Watch Post Orders,
1/20/2019 letter from Manday Strickland requesting records re protest at
Irick's execution, surveillance pictures of protesters and Protester sign-in
sheet for David Miller produced in King v. Parker – Middle District of
Tennessee proceedings

1018.

Redacted 1/3/2018 emails re [Pharmacy] invoices, 2/20/2018 TDOC
agreement with provider, 1/22/2018 email re [Pharmacy] invoice, 2018 2019 lethal drug inventory logs, TDOC Tennessee Board of Pharmacy
license, July and August 2018, Oct 2018, February 2019 and August 2019
[Pharmacy] invoices, Screenshot of TDOC payments to [Pharmacy], 2018
accounts payable records, 11/27/2017 Pharmacy Services Agreement,
TDOC - RMSI's Procurement, Preparation, Introduction of the Lethal
Injection Chemical, and Procedures of Accountability policies and
procedures, rev 7/5/2018, Midazolam storage and preparation instructions,
and Potassium Chloride preparation instructions produced in King v.
Parker – Middle District of Tennessee proceedings (61 pages)

1019.

8/28/2019 draft of letter from Debra Inglis responding to 8/23/2019 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1020.

10/4/2019 Letter from Debra Inglis providing records in response to
8/23/2019 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

1021.

10/4/2019 draft of letter from Debra Inglis providing records in response to
8/23/2019 request for records produced in King v. Parker – Middle District
of Tennessee proceedings

111

BU TLE R I SNOW
1022.

12/14/2018 Letter from Debra Inglis responding to 12/6/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

1023.

1/15/2019 Letter from Debra Inglis providing cost for records in response
to 12/6/2018 request produced in King v. Parker – Middle District of
Tennessee proceedings

1024.

Redacted Dec 2017 - 2018 lethal drug inventory logs, TDOC [Pharmacy]
vendor payments, 2017 - 2018 [Pharmacy] invoices, 11/27/2017 Pharmacy
Services Agreement, 2017-2018 Emails re procuring lethal drugs, supplier
payments, protocols, supplies received, the use of other potential lethal
drugs, and Pharmaceutical letters re misuse of products produced in King v.
Parker – Middle District of Tennessee proceedings (121 pages)

1025.

Redacted 12/30/2017 - 2018 lethal drug inventory logs produced in King v.
Parker – Middle District of Tennessee proceedings (3 pages)

1026.

12/14/2018 draft letter from Debra Inglis responding to 12/6/2018 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1027.

1/15/2019 Letter from Debra Inglis responding to 12/6/2018 request for
records with costs produced in King v. Parker – Middle District of
Tennessee proceedings

1028.

Redacted 7/5/2018, 8/16/2018 and 10/31/2018 [Pharmacy] Invoices
produced in King v. Parker – Middle District of Tennessee proceedings (3
pages)

1029.

12/6/2018 Letter from Seamus Kelly requesting records re lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

1030.

Redacted 2016-2018 electric chair and equipment inspection and testing
logs produced in King v. Parker – Middle District of Tennessee
proceedings (5 pages)

1031.

Redacted 10/2018 – 12/2018 Training rosters for electrocution protocol,
electric chair, and training materials, redacted 2017 -2018 invoices, and
electrocution policies and procedures, rev. 7/11/2016 produced in King v.
Parker – Middle District of Tennessee proceedings (150 pages)

1032.

12/12/2018 Letter from Debra Inglis responding to 10/22/2018 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

112

BU TLE R I SNOW
1033.

TDOC Electrocution policies and procedures, rev. 3/13/2017 produced in
King v. Parker – Middle District of Tennessee proceedings (88 pages)

1034.

Redacted emails and letters re attendance at Zagorski's execution, Internal
and External media list for execution, media elections to attend execution,
letters/emails from Zagorski's attorney re execution, Zagorski execution
affidavits, execution notification letter, Victim services emails and
correspondence, Microsoft outlook notifications for visits, emails re
visitation, Zagorski note and memo re no family attending execution and
last meal, TDOC offender info, and Zagorski request not to have autopsy
performed after execution produced in King v. Parker – Middle District of
Tennessee proceedings (187 pages)

1035.

10/22/2018 Letter from Seamus Kelly requesting records re electric chair
and Zagorski's upcoming execution produced in King v. Parker – Middle
District of Tennessee proceedings

1036.

Redacted 11/2016 – 10/2018 Training rosters for electrocution practice,
protocol for execution, electrocution and lethal injection, execution,
electrocution death watch, electric chair, and training materials produced in
King v. Parker – Middle District of Tennessee proceedings (133 pages)

1037.

4/29/2020 Letter from Rivkin requesting records re lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

1038.

5/6/2020 Letter from [Drug Procurer] encl records in response to 4/9/2020
request produced in King v. Parker – Middle District of Tennessee
proceedings

1039.

Redacted 2/11/2020, 12/20/2019 and 12/6/2019 [Pharmacy] invoices,
9/2019 – 12/2019 emails re [Pharmacy] invoices/payments, lab results,
lethal drug sources, procuring lethal drugs, 9/2019 – 2/2020 lethal drug
inventory logs produced in King v. Parker – Middle District of Tennessee
proceedings (14 pages)

1040.

Redacted lethal inventory log for 9/2019 – 12/2019 produced in King v.
Parker – Middle District of Tennessee proceedings

1041.

12/11/2020 Letter from [Drug Procurer] in response to 12/9/2020 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1042.

5/22/2020 Letter from [Drug Procurer] in response to 4/29/2020 follow up
request produced in King v. Parker – Middle District of Tennessee
proceedings

113

BU TLE R I SNOW
1043.

6/8/2020 letter from [Drug Procurer] in response to 4/29/2020 additional
follow up request produced in King v. Parker – Middle District of
Tennessee proceedings

1044.

Redacted 9/29/2021 email re lethal drug and supply orders, 7/26/2021
lethal drug inventory, Midazolam and potassium chloride Inventory and
Use logs produced in King v. Parker – Middle District of Tennessee
proceedings (8 pages)

1045.

10/9/2021 letter from Rivkin requesting records re lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

1046.

Redacted 7/2020 – 12/2020 Training rosters for electrocution, electrocution
and lethal injection protocol review, lethal injection, electrocution and
lethal injection strap down team, and training materials, redacted 8/2020 –
11/2020 emails re lethal drugs inventory, sterile compounding training
requirements, payments, invoices, attaching inventory logs for midazolam
and potassium chloride, info re payments made to [Pharmacy] and
invoices, pharmaceutical letters re misuse of products and 2/2020 redacted
lethal drug inventory log produced in King v. Parker – Middle District of
Tennessee proceedings (122 pages)

1047.

1048.

Redacted Training rosters for electrocution, lethal injection, electrocution
and lethal injection protocol review, electrocution and lethal injection
strapdown, redacted 8/2020 – 11/2020 emails re lethal drugs inventory,
sterile compounding training requirements, payments, invoices, attaching
inventory logs for midazolam and potassium chloride, info re payments
made to [Pharmacy] and invoices, pharmaceutical letters re misuse of
products and 2/2020 redacted lethal drug inventory log produced in King v.
Parker – Middle District of Tennessee proceedings (129 pages)

1049.

TDOC Electrocution policies and procedures, rev. 3/13/2017, Redacted
7/29/2020 Training rosters for lethal injection and training materials,
redacted 7/28/2020 [Pharmacy] Invoice, Redacted 1/2020 – 7/2020 training rosters for lethal injection, electrocution, protocol, and training

114

BU TLE R I SNOW
materials produced in King v. Parker – Middle District of Tennessee
proceedings (150 pages)
1050.

TDOC policies and procedures re Death Watch, Execution Team, Death
Watch Supervisor and Control Monitor, rev. 3/13/2017 produced in King v.
Parker – Middle District of Tennessee proceedings (11 pages)

1051.

1/15/2021 Letter from [Drug Procurer] in response to 12/9/2020 request for
records and enclosing TDOC Lethal Injection Execution Manual, rev
7/5/2018, and TDOC Electrocution Execution Manual, rev. 3/13/2017
produced in King v. Parker – Middle District of Tennessee proceedings
(146 pages)

1052.

12/9/2020 request for records from Rivkin re lethal injection and
electrocution produced in King v. Parker – Middle District of Tennessee
proceedings

1053.

Redacted 2/20/2020 – 11/12/2020 electric chair testing logs produced in
King v. Parker – Middle District of Tennessee proceedings

1054.

12/9/2020 letter from Rivkin requesting records re lethal injection and
electrocution produced in King v. Parker – Middle District of Tennessee
proceedings

1055.

1/4/2021 Letter from [Drug Procurer] responding to 12/9/2020 request for
records with cost info produced in King v. Parker – Middle District of
Tennessee proceedings

1056.

Redacted 1/26/2021 [Pharmacy] Invoice produced in King v. Parker –
Middle District of Tennessee proceedings

1057.

6/10/2021 Letter from [Drug Procurer] providing records in response to
6/4/2021 request produced in King v. Parker – Middle District of
Tennessee proceedings

1058.

6/10/2021 Draft of letter from [Drug Procurer] providing records in
response to 6.4.21 request produced in King v. Parker – Middle District of
Tennessee proceedings

1059.

6/4/2021 request for records from Rivkin re lethal injection produced in
King v. Parker – Middle District of Tennessee proceedings

1060.

8/12/2020 Letter from Rivkin requesting records re lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

115

BU TLE R I SNOW
1061.

8/17/2020 Letter from [Drug Procurer] responding to 8/12/2020 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

1062.

8/27/2020 draft letter from [Drug Procurer] following up to 8/12/2020
request for records produced in King v. Parker – Middle District of
Tennessee proceedings

1063.

Redacted 7/28/2020 Invoice from [Pharmacy] and 2/11/2020 and 8/4/2020
Lethal drugs inventory log produced in King v. Parker – Middle District of
Tennessee proceedings

1064.

Redacted 2/11/2020 and 8/4/2020 Lethal drugs inventory log produced in
King v. Parker – Middle District of Tennessee proceedings

1065.

12/11/2020 Letter from [Drug Procurer] responding to 12/9/2020 request
for records produced in King v. Parker – Middle District of Tennessee
proceedings

1066.

8/18/2020 Letter from Rivkin follow up request for records re lethal drugs
produced in King v. Parker – Middle District of Tennessee proceedings

1067.

Redacted 7/22/2020 email re midazolam and kcl potency results and
7/28/2020 Invoice from [Pharmacy] produced in King v. Parker – Middle
District of Tennessee proceedings

1068.

7/22/2020 email from [Pharmacist] re midazolam and kcl potency results
and 7/28/2020 Invoice from [Pharmacy] produced in King v. Parker –
Middle District of Tennessee proceedings

1069.

8/27/2020 letter from [Drug Procurer] following up to 8/12/2020 request
for records and enclosing redacted 7/22/2020 email re midazolam and kcl
potency results and 7/28/2020 Invoice from [Pharmacy] produced in King
v. Parker – Middle District of Tennessee proceedings

1070.

10/9/2019 Letter requesting records re communications between TDOC
and Idaho state actors re lethal injection produced in King v. Parker –
Middle District of Tennessee proceedings

1071.

10/24/2019 Letter from Debra Inglis responding to 10/9/2019 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

1072.

Redacted Jan 2017 - Dec 2017 training rosters re Execution, Electrocution
and Lethal Injection protocol review, Death Watch, Practice, Protocol

116

BU TLE R I SNOW
Review, Lethal Injection, and training materials produced in King v.
Parker – Middle District of Tennessee proceedings (107 pages)
1073.

6/19/2018 Letter from [Drug Procurer] providing records in partial
response to records request produced in King v. Parker – Middle District of
Tennessee proceedings

1074.

5/9/2018 Letter from [Drug Procurer] responding to records request with
info re records that are confidential and cost produced in King v. Parker –
Middle District of Tennessee proceedings

1075.

7/17/2018 Draft letter from [Drug Procurer] responding to records request
with info re records that are confidential and cost produced in King v.
Parker – Middle District of Tennessee proceedings

1076.

4/12/2018 letter from [Drug Procurer] responding to records request
produced in King v. Parker – Middle District of Tennessee proceedings

1077.

6/27/2018 request for records re lethal injection and 7/17/2018 response
with info re records that are confidential and cost produced in King v.
Parker – Middle District of Tennessee proceedings

1078.

2/23/2018 request for records re lethal injection produced in King v. Parker
– Middle District of Tennessee proceedings

1079.

Redacted Jan 2017 - Dec 2017 training rosters re Execution, Electrocution
and Lethal Injection protocol review, Death Watch, Practice, Protocol
Review, Lethal Injection, and training materials produced in King v.
Parker – Middle District of Tennessee proceedings (107 pages)

1080.

1/5/2018 Letter from [Drug Procurer] in response to 12/13/2017 request for
records and 12/13/2017 and 10/16/2017 records request re lethal injection
produced in King v. Parker – Middle District of Tennessee proceedings

1081.

Subpoena to Tony Parker re Ohio Execution Protocol Litigation requesting
records re execution documents for Irick and Johnson produced in King v.
Parker – Middle District of Tennessee proceedings

1082.

Redacted Record of Staff Visits, Day of Execution - Lethal Injection
Execution Recorder, and TDOC Incident Report for Charles Walton
Wright produced in King v. Parker – Middle District of Tennessee
proceedings (18 pages)

1083.

117

BU TLE R I SNOW
execution, Method of Execution letter, Microsoft Outlook notifications re
visits, TDOC Offender info and Incident Reports for execution, TDOC
visitation records, spiritual advisor at execution selection, records re TDOC
preparation for execution, Johnson clemency records, Death Watch logs,
5/9/2019 lethal drug inventory log, Johnson mug shot, and record of staff
visits produced in King v. Parker – Middle District of Tennessee
proceedings. (188 pages)
1084.

Affidavit of Records Custodian signed by [Drug Procurer] produced in
King v. Parker – Middle District of Tennessee proceedings

1085.

Redacted Media information and selections for execution of Irick, and
letter to counsel requesting info re attorneys on site during death watch
produced in King v. Parker – Middle District of Tennessee proceedings (41
pages)

1086.

Redacted July 2018 - August 2018 training rosters re lethal injection and
training materials, Death Watch logs, lethal drugs prescription for Irick,
Midazolam storage and preparation instructions, TDOC Incident Report,
Affidavits re defense counsel selection to attend execution and method of
execution, Method of execution letter, Day of Execution - Lethal Injection
Execution Recorder Checklist, Victim services forms and letters re
execution and attendance at execution produced in King v. Parker –
Middle District of Tennessee proceedings (150 pages)

1087.

1088.

Affidavit of Records Custodian signed by [Drug Procurer] produced in
King v. Parker – Middle District of Tennessee proceedings

1089.

2018 - 2019 Redacted electric chair testing logs produced in King v. Parker
– Middle District of Tennessee proceedings

1090.

Redacted Jan 2018 - emails re [Pharmacy] Invoices, Provider Agreement,
July 2018 - November 2018 Lethal drugs inventory logs, May 9, 2019
Midazolam Inventory, Tennessee Board of Pharmacy license, February
2019 - August 2019 [Pharmacy] Invoices, Vendor records, Pharmacy
Services Agreement, TDOC policies and procedures re Procurement,
Preparation, Introduction of the lethal Injection Chemical and Procedures
of Accountability, rev. 7/5/2018, Midazolam storage and preparation
instructions and KCL preparation instructions produced in King v. Parker –
Middle District of Tennessee proceedings (61 pages)

118

BU TLE R I SNOW
1091.

8/26/2019 Letter from Debra Inglis responding to 8/22/2019 request for
records produced in King v. Parker – Middle District of Tennessee
proceedings

1092.

Draft of 8/26/2019 Letter from Debra Inglis responding to 8/22/2019
request for records produced in King v. Parker – Middle District of
Tennessee proceedings

1093.

Draft of 1/13/2020 Letter from Debra Inglis responding to 1/9/2020 follow
up request for records produced in King v. Parker – Middle District of
Tennessee proceedings

1094.

11/22/2019 Letter from Debra Inglis providing records in response to
11/1/2019 request, July 2018 - Aug 2019 lethal drug inventory logs, vendor
invoices and payments, Feb 2019 - Aug 2019 [Pharmacy] Invoices
produced in King v. Parker – Middle District of Tennessee proceedings (15
pages)

1095.

Draft of 9/25/2019 letter from Debra Inglis providing records in response
to 8/22/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

1096.

11/22/2019 Draft letter from Debra Inglis providing records in response to
11/1/2019 request produced in King v. Parker – Middle District of
Tennessee proceedings

1097.

11/15/2019 Letter from Debra Inglis responding to 11/1/2019 request for
additional records produced in King v. Parker – Middle District of
Tennessee proceedings

1098.

9/17/2019 Letter from Debra Inglis responding to 8/22/2019 request for
records with cost produced in King v. Parker – Middle District of
Tennessee proceedings

1099.

8/22/2019 Letter requesting records re lethal injection produced in King v.
Parker – Middle District of Tennessee proceedings

1100.

9/20/2018 filed Motion to Stay Proceedings based on Colorado River
Abstention Doctrine and Memo of Law in Support produced in King v.
Parker – Middle District of Tennessee proceedings

1101.

8/21/2018 Complaint for Injunctive Relief produced in King v. Parker –
Middle District of Tennessee proceedings

1102.

Outline of new website

119

BU TLE R I SNOW
1103.

United States Pharmacopeial Convention guidance

1104.

[Pharmacy]'s current Texas pharmacy license expiring 4/30/2024

1105.

Unsigned Pharmacy Services Agreement between [Pharmacy] and TDOC

1106.

[Pharmacy]'s 6/26/2018 Application to Add License Modifier to Tennessee
Board of Pharmacy, attaching [Pharmacist]-in-Charge compounding
information, [Pharmacy]'s ownership and management information, Texas
Board of Pharmacy disciplinary action and inspection reports, DEA
License and List of Reference books

1107.

12/8/2017 Letter to Texas State Board of Pharmacy from [Pharmacy] re the
pharmacy's suspension of sterile compounding.

1108.

April 2018 [Pharmacy] Application to Change Pharmacy License
Classification to Compounding Sterile Preparations.

1109.

11/27/2017 signed Pharmacy Services Agreement between [Pharmacy] and
TDOC.

1110.

7/18/2018 Billy Ray Irick Prescription for Midazolam

1111.

List of sterile compounding pharmacies in Tennessee

1112.

Redacted formula for Midazolam

1113.

Formula for Midazolam

1114.

12/8/2017 Letter to Texas State Board of Pharmacy from [Pharmacy] re the
pharmacy's suspension of sterile compounding.

1115.

April 2018 [Pharmacy] Application to Change Pharmacy License
Classification to Compounding Sterile Preparations.

1116.

Blank order form for Midazolam, Vecuronium Bromide and Potassium
Chloride

1117.

2016 Texas State Board of Pharmacy Notice of Inspection

1118.

2014 Texas Board of Pharmacy Agreed Order for Sun City Compounding,
LLC signed by [Former Pharmacy Owner]

1119.

Information regarding Beyond Use Dates on compounded sterile
preparations

120

BU TLE R I SNOW
1120.

Blank sample pharmacy agreement between Riverbend Maximum Security
and a [Pharmacist], rev 6/25/2015

1121.

6/15/2018 Email from [Former Pharmacy Owner] to [Drug Procurer]
enclosing Beyond Use Dating for Sterile Compounding information

1122.

[Pharmacy]'s Texas pharmacy license expiring 4/30/2018

1123.

2016 Texas State Board of Pharmacy Notice of Inspection

1124.

5/22/2018 Midazolam method suitability test result

1125.

5/11/2018 Midazolam potency, bacterial endotoxins and sterility test
results

1126.

5/14/2018 Midazolam container closure integrity test result

1127.

Dashboard reflecting 2017-2019 [Pharmacy] Invoices and payments

1128.

Redacted [Pharmacy] Invoices

1129.

2017 - 2019 [Pharmacy] Invoices

1130.

[Pharmacy]'s current Texas pharmacy license expiring 4/30/2024

1131.

[Pharmacy]'s Tennessee pharmacy license expiring 7/31/2022

1132.

[Pharmacy]'s current DEA license expiring 2/28/2023

1133.

2/26/2020 Letter from Hikma Pharmaceuticals objecting to the use of its
products in capital punishment and requesting confirmation that TDOC is
not in possession of any Hikma/West Ward products

1134.

8/15/2019 Letter from Sandoz objecting to the use of its products in capital
punishment and demanding the return of any products in TDOC's
possession

1135.

8/2/2018 Letter from Sandoz objecting to the use of its products in capital
punishment and demanding the return of any products in TDOC's
possession

1136.

8/15/2019 Letter from Sandoz objecting to the use of its products in capital
punishment and demanding the return of any products in TDOC's
possession

121

BU TLE R I SNOW
1137.

Redacted text messages from Oct 2017 - April 2018 re lethal drugs
procurement produced in response to public records request (17 pages)

1138.

Draft 6/10/2019 Letter from Tennessee Office of the Attorney General
responding to 6/4/2019 request for records produced in response to public
records request

1139.

Redacted 12/2017 Order for Midazolam, Vecuronium Bromide and
Potassium Chloride produced in response to public records request

1140.

11/13/2019 Draft letter from [Drug Procurer] responding to 11/6/2019
request for records with costs produced in response to public records
request

1141.

11/22/2019 Draft letter from [Drug Procurer] responding to 11/6/2019
request for records with costs produced in response to public records
request

1142.

Redacted lethal drug procurement handwritten notes produced in response
to public records request (6 pages)

1143.

Unredacted April 2017 - April 2018 text messages between [Drug
Procurer] and [Former Pharmacy Owner] re lethal drugs procurement
produced in response to public records request (23 pages)

1144.

Unredacted September 2019 - December 2019 lethal drug inventory logs
produced in response to public records request

1145.

Redacted July 2018 Training rosters for lethal injection, protocol review,
and training materials produced in response to public records request (25
pages)

1146.

Redacted April 2017 - April 2018 text messages between [Drug Procurer]
and [Former Pharmacy Owner] re lethal drugs procurement produced in
response to public records request (23 pages)

1147.

8/13/2018 Letter from Debra Inglis requesting the return of documents
provided in response to public record requests that have led to the
discovery of individuals/entities involved in the lethal execution process
produced in response to public records request

1148.

4/15/2019 Letter from Debra Inglis responding to 3/28/2019 request for
records with costs produced in response to public records request

1149.

2/18/2022 Draft Letter from Debra Inglis responding to 2/11/2022 request
for records produced in response to public records request

122

BU TLE R I SNOW
1150.

4/4/2022 Draft Letter from Debra Inglis responding to 3/18/2022 request
for records produced in response to public records request

1151.

3/3/2022 Draft Letter from Debra Inglis responding to 3/2/2022 request for
records produced in response to public records request

1152.

6/8/2020 Draft Letter from Debra Inglis responding to 5/29/2020 request
for records with cost produced in response to public records request

1153.

March 2022 Draft Letter from Debra Inglis responding to 3/2/2022 request
for records produced in response to public records request

1154.

2/12/2018 Draft Letter from [Drug Procurer] responding to request for
records received 2/6/2018 and asking for the requester to narrow the scope
produced in response to public records request

1155.

Redacted Feb 2017 - Sept 2017 emails re lethal drug procurement,
9/1/2016 Authorization to dispense Prescriptions for Schedule II
Controlled Substances, Declaration regarding chemical products intended
use, Aug 2015 and Feb 2017 - July 2017 redacted training rosters re lethal
injection, Electrocution, Death Watch, Execution protocols for lethal
injection and electrocution, and training materials, and Execution
Procedures for Electrocution, rev Mar 13, 2017 produced in response to
public records request

1156.

Unredacted July 2018 - August 2019 lethal drug inventory logs produced
in response to public records request (10 pages)

1157.

Redacted 7/10/2018 Training roster for Execution Protocol produced in
response to public records request

1158.

Redacted 6/13/2018 Training roster for lethal injection and training
materials produced in response to public records request (10 pages)

1159.

Unredacted 6/13/2018 Training roster for lethal injection and training
materials produced in response to public records request (10 pages)

1160.

Redacted 4/13/2022 lethal drugs inventory produced in response to public
records request

1161.

Unredacted 12/20/2017 order for Midazolam, Vecuronium Bromide and
Potassium Chloride, TDOC DEA licenses and Unredacted 2017
[Pharmacy] Invoices for lethal drugs signed as received by TDOC staff
produced in response to public records request (8 pages)

123

BU TLE R I SNOW
1162.

11/3/2021 request for records re lethal injection, electrocution and
execution produced in response to public records request

1163.

Redacted April 2021 - Oct 2021 Electric chair testing logs, July 2021 - Nov
2021 Training rosters re Protocol Review, Lethal Injection, Electrocution,
Strap down team, and training materials, redacted July 2021 - emails re
training logs, docs needed for discovery responses, lethal drugs and supply
procurement, Tennessee Board of Pharmacy license, DEA license,
Inventory and Use logs for Potassium Chloride, Midazolam, and 7/26/2021
lethal drug inventory logs produced in response to public records request
(127 pages)

1164.

Unredacted 7/26/2021 lethal drug inventory log produced in response to
public records request

1165.

Unredacted 7/26/2021 lethal drug inventory log produced in response to
public records request

1166.

11/15/2021 letter from Debra Inglis responding to 11/3/2021 request for
records produced in response to public records request

1167.

1/12/2022 Request for records re lethal injection produced in response to
public records request

1168.

1/31/2022 Email from [Drug Procurer] to Robert Reburn enclosing
responsive docs to records request produced in response to public records
request

1169.

Redacted Nov 2021 - emails re lethal drugs and supplies procurement,
redacted 11/30/2021 [Pharmacy] Invoice and redacted lethal drugs
inventory log produced in response to public records request

1170.

3/1/2022 Email from [Drug Procurer] enclosing 3/1/2022 email from [Drug
Procurer] to Robert Reburn with docs responsive to records request
produced in response to public records request

1171.

Redacted Nov 2021 - Emails re lethal drugs procurement, Redacted Oct
2021 - Feb 2022 Training rosters re protocol, Electrocution, Lethal
Injection, Strap down Team, and training materials produced in response to
public records request

1172.

2/9/2022 Email from Robert Reburn to [Drug Procurer] forwarding follow
up request for records produced in response to public records request

1173.

Redacted lethal drugs inventory log produced in response to public records
request

124

BU TLE R I SNOW
1174.

3/8/2022 Email from Robert Reburn to [Drug Procurer] forwarding
3/8/2022 request for records re lethal injection produced in response to
public records request

1175.

4/13/2022 Email from [Drug Procurer] to Robert Reburn enclosing
responsive docs to request for records produced in response to public
records request

1176.

Redacted March 2022 - April 2022 Emails re lethal drugs and supplies
procurement produced in response to public records request

1177.

4/6/2022 request for records re lethal injection produced in response to
public records request

1178.

Unredacted March 2022 - April 2022 Emails between [Drug Procurer] and
[Pharmacist] re lethal drugs and supplies procurement produced in
response to public records request

1179.

5/3/2022 Email from Robert Reburn to [Drug Procurer] forwarding request
for records produced in response to public records request

1180.

Redacted April 2022 - May 2022 Emails re lethal drugs procurement and
supplies, executions, and Oscar Smith reprieve, sterile compounding info,
Redacted 4/12/2022 [Pharmacy] Invoice, Tennessee Board of Pharmacy
license and DEA license, 4/21/2022 text message inquiring about whether
chemicals needed to be maintained in the event of a challenge, 5/11/2022
email attaching text messages re Smith's reprieve, 4/21/2022 text messages
re lethal drugs and preserving the drugs, April 2022 text messages re lethal
drugs and testing reports, 4/21/2022 text messages re halting lethal drugs
preparation, 5/11/2022 Inventory & Use logs for Midazolam and Potassium
Chloride, and 4/13/2022 and 4/21/2022 lethal drugs inventory logs
produced in response to public records request

1181.

5/12/2022 request for records re lethal drugs produced in response to
public records request

1182.

5/31/2022 Email from Robert Reburn to [Drug Procurer] forwarding
5/12/2022 records request re lethal drugs produced in response to public
records request

1183.

6/8/2022 Email from Robert Reburn to [Drug Procurer] forwarding follow
up request for records produced in response to public records request

1184.

Redacted text messages re lethal drugs preparation, 4/21/2022 lethal drugs
inventory logs, Smith Reprieve, 10/22/2018 entered Order setting

125

BU TLE R I SNOW
Zagorski's execution date and 5/12/2022 redacted emails re training
produced in response to public records request
1185.

April 13, 2022 unredacted lethal drugs inventory log produced in response
to public records request

1186.

3/23/2022 Email from [Drug Procurer] to Dorinda Carter enclosing records
responsive to request produced in response to public records request

1187.

Redacted 3/16/2022 emails re lethal drugs procurement, 11/30/2021
[Pharmacy] Invoice and lethal drugs inventory log produced in response to
public records request

1188.

3/22/2022 Email from Dorinda Carter to [Drug Procurer] forwarding
3/16/2022 request for records re lethal drugs produced in response to
public records request

1189.

Unredacted Jan 2022 - April 2022 emails between [Drug Procurer] and
[Pharmacist] re [Pharmacy] invoices and lethal drugs procurement,
11/30/2021 and 4/12/2022 [Pharmacy] Invoices and 4/13/2022 lethal drugs
inventory log produced in response to public records request

1190.

Subpoena to Tony Parker re Ohio Execution Protocol Litigation requesting
records re execution documents for Irick and Johnson produced in
response to public records request

1191.

Redacted Record of Staff Visits, Day of Execution - Lethal Injection
Execution Recorder, and TDOC Incident Report for Charles Walton
Wright produced in response to public records request

1192.

Redacted Johnson inmate card, Media information and selections for
execution, victim services and attendance at execution emails and letters,
Affidavits re defense counsel to witness execution and method of
execution, Method of Execution letter, Microsoft Outlook notifications re
visits, TDOC Offender info and Incident Reports for execution, TDOC
visitation records, spiritual advisor at execution selection, records re TDOC
preparation for execution, Johnson clemency records, Death Watch logs,
5/9/2019 lethal drug inventory log, Johnson mug shot, and record of staff
visits produced in response to public records request.

1193.

Affidavit of Records Custodian signed by [Drug Procurer] produced in
response to public records request

1194.

Redacted Media information and selections for execution, and letter to
counsel requesting info re attorneys on site during death watch produced in
response to public records request

126

BU TLE R I SNOW
1195.

1196.

Redacted Media information and selections for execution, and letter to
counsel requesting info re attorneys on site during death watch produced in
response to public records request

1197.

Affidavit of Records Custodian signed by [Drug Procurer] produced in
response to public records request

1198.

2018 - 2019 Redacted electric chair testing logs produced in response to
public records request

1199.

12/3/2018 email from Neysa Taylor forwarding request for electric chair
testing records produced in response to public records request

1200.

Text messages re lethal drugs and prep produced in response to public
records request (7 pages)

1201.

Text messages re lethal drugs and prep produced in response to public
records request (7 pages)

1202.

Text messages re lethal drugs and prep produced in response to public
records request (3 pages)

1203.

Text messages re lethal drugs and prep produced in response to public
records request

1204.

Text messages re lethal drugs and prep produced in response to public
records request

1205.

Text messages re lethal drugs and prep produced in response to public
records request

1206.

Text message re preserving evidence produced in response to public
records request

1207.

Letter responding to TPRA re records for scheduled execution of Smith
produced in response to public records request

127

BU TLE R I SNOW
1208.

Training logs and materials, 4/21/2022 drug inventory, 4/12/2022
[Pharmacy] invoice for drugs, emails between [Drug Procurer] and
[Pharmacist] produced in response to public records request (44 pages)

1209.

1210.

Open records requests from media, TDOC policies and procedures re
TPRA, form for requesting records and blank forms. produced in response
to public records request

1211.

Training logs and materials produced in response to public records request
(114 pages)

1212.

Training logs and materials produced in response to public records request
(112 pages)

1213.

Emails and text messages re Smith on death watch and status of execution
produced in response to public records request (26 pages)

1214.

Reprieve docs, emails and text messages produced in response to public
records request (7 pages)

1215.

Reprieve docs, emails and text messages produced in response to public
records request (7 pages)

1216.

Template for responses to media seeking TPRA re Smith produced in
response to public records request

1217.

TPRA request for records re Smith's execution produced in response to
public records request

1218.

4/26/2022 Letter from counsel for Harold Wayne Nichols req recs related
to Smith's 4/21/2022 execution date, permission to inspect and photograph
items and request re Nichols' pending execution produced in response to
public records request

1219.

4/29/2022 Letter from Inglis responding to Federal Public Defender's
request seeking records re Oscar Smith's execution produced in response to
public records request

1220.

4/25/2022 Letter from Federal Public Defender's seeking records re Oscar
Smith's execution produced in response to public records request

128

BU TLE R I SNOW
1221.

4/29/2022 Letter from Inglis responding to Federal Public Defender's
request seeking records re Oscar Smith's execution produced in response to
public records request

1222.

4/29/2022 Letter from Inglis responding to Federal Public Defender's
request produced in response to public records request

1223.

Debbie Inglis emails preserved per Order produced in response to public
records request (100 pages)

1224.

4/20/2022 -4/21/2022 Text messages re drugs produced in response to
public records request

1225.

4/20/2022 -4/21/2022 Text messages re drugs produced in response to
public records request

1226.

4/20/2022 -4/21/2022 Text messages re drugs produced in response to
public records request

1227.

Delegation Authority Amendments for Execution related services in 2019
produced in response to public records request (14 pages)

1228.

Delegation Authority Amendments for Execution related services in 2018
produced in response to public records request (9 pages)

1229.

Delegated Authority for Execution related services in 2022 produced in
response to public records request (7 pages)

1230.

Delegated Authority for Execution related services in 2021 produced in
response to public records request (7 pages)

1231.

Delegated Authority for Execution related services in 2020 produced in
response to public records request (7 pages)

1232.

Redacted Inmate clothing card produced in response to public records
request

1233.

Inmate clothing card produced in response to public records request

1234.

Redacted Death watch logs produced in response to public records request
(5 pages)

1235.

Death watch logs produced in response to public records request (5 pages)

1236.

Redacted Death watch logs produced in response to public records request
(5 pages)

129

BU TLE R I SNOW
1237.

Death watch logs produced in response to public records request (5 pages)

1238.

Redacted Death watch logs produced in response to public records request
(6 pages)

1239.

Death watch logs produced in response to public records request (6 pages)

1240.

Redacted Record of staff visits produced in response to public records
request (7 pages)

1241.

Record of staff visits produced in response to public records request (7
pages)

1242.

Redacted TDOC disciplinary record, Inmate Grievance records, Emails re
execution day parking and email re other offenders produced in response
to public records request (8 pages)

1243.

TDOC disciplinary record, Inmate Grievance records, Emails re execution
day parking and email re other offenders produced in response to public
records request (8 pages)

1244.

Redacted Electric chair testing log produced in response to public records
request

1245.

Electric chair testing log produced in response to public records request

1246.

Redacted Visitation records produced in response to public records request
(22 pages)

1247.

Visitation records produced in response to public records request (22
pages)

1248.

TDOC execution day parking document produced in response to public
records request (6 pages)

1249.

TDOC offender info produced in response to public records request

1250.

Inmate inquiry forms and property inventories produced in response to
public records request (10 pages)

1251.

Redacted Refusal of medical services and TDOC medical history form
produced in response to public records request (4 pages)

1252.

Refusal of medical services and TDOC medical history form produced in
response to public records request (4 pages)

130

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1253.

Redacted Spiritual advisor records produced in response to public records
request (44 pages)

1254.

Spiritual advisor records produced in response to public records request
(44 pages)

1255.

Last meal request produced in response to public records request

1256.

Redacted Email encl Smith's Method of Execution and notification letter
produced in response to public records request (3 pages)

1257.

Email encl Smith's Method of Execution and notification letter produced in
response to public records request (3 pages)

1258.

Smith orders and filings produced in response to public records request
(64 pages)

1259.

Redacted Sheriff attendance at execution records produced in response to
public records request (7 pages)

1260.

Sheriff attendance at execution records produced in response to public
records request (7 pages)

1261.

Redacted Attorney general attendance at execution records produced in
response to public records request (3 pages)

1262.

Attorney general attendance at execution records produced in response to
public records request (3 pages)

1263.

Redacted Email encl letters to be mailed to victims' family members re
execution produced in response to public records request (44 pages)

1264.

Email encl letters to be mailed to victims' family members re execution
produced in response to public records request (44 pages)

1265.

Redacted Letters to Smith's counsel, Affidavit to Select Defense Counsel
Witness to Execution and emails re legal visits produced in response to
public records request (14 pages)

1266.

Letters to Smith's counsel, Affidavit to Select Defense Counsel Witness to
Execution and emails re legal visits produced in response to public records
request (14 pages)

131

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1267.

Redacted Records re media and communications personnel on execution
day produced in response to public records request (13 pages)

1268.

Records re media and communications personnel on execution day
produced in response to public records request (13 pages)

1269.

Text messages re chemicals and execution preparation produced in
response to public records request (3 pages)

1270.

Delegations of Authority for execution related services, training logs and
materials, drug inventory logs, drug invoice, pharmacy records, emails re
drugs, media lottery recs for witnessing execution, emails re visits from
counsel, victim service records, letters re election to attend execution,
Smith orders and filings, Affidavit Concerning Method of Execution,
notification letter, last meal inquiry form, spiritual advisor forms and
records, Inmate Inquiry forms, personal property log, Tool Inventory,
TDOC Offender info, visitation records, TDOC disciplinary records,
Inmate Grievances, Death watch logs, Inmate clothing card and record of
staff visits produced in response to public records request (361 pages)

1271.

[Pharmacy] Midazolam inventory, 3/7/2018 – 4/5/2022 produced in
response to public records request (4 pages)

1272.

Midazolam inventory, 3/7/2018 – 4/5/2022 and Potassium Chloride
inventory, 7/8/2019 – 10/11/2021 produced in response to public records
request (12 pages)

1273.

Reprieve records and emails, text messages re drugs produced in response
to public records request (15 pages)

1274.

4/21/2022 emails attaching Zagorski order setting execution date and
Zagorski reprieve produced in response to public records request

1275.

Sterile compounding records produced in response to public records
request (18 pages)

1276.

Spiritual advisor records, NDA for spiritual advisor, letters, inmate inquiry
forms, inmate personal property logs, TDOC offender info, visitation
records, TDOC disciplinary records, Inmate Grievance records, Death
watch logs and Record of staff visits produced in response to public
records request (96 pages)

1277.

Training materials and logs, lethal drug inventories, invoice for drugs,
Tennessee Pharmacy license, DEA card, emails re drug orders, media
lottery drawing records, letter to counsel re execution, emails re legal
visits, Victim services records, Smith orders and filings, Affidavits re

132

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counsel attending execution and method of execution, notification letter
and last meal inmate inquiry produced in response to public records
request (147 pages)
1278.

Delegations of Authority for execution related services, training logs and
materials produced in response to public records request (118 pages)

1279.

Delegations of Authority for execution related services, training logs and
materials produced in response to public records request (118 pages)

1280.

5/13/2022 draft letter from Debra Inglis providing records in response to
5/12/2022 request re Oscar Smith's scheduled execution

1281.

5/13/2022 draft letter from Debra Inglis providing records in response to
4/22/2022 request re Oscar Smith's scheduled execution produced in
response to public records request

1282.

Finley, Keefe, Kruesi, Loller, Timms and Vaughan responsive docs to
TPRA requests for Oscar Smith and executions enclosing redacted MayApril 2022 emails re Smith's reprieve, statement on Smith's temporary
reprieve, Governor’s reprieve, redacted April 2022 emails re Zagorski's
order setting execution date and reprieve, redacted Delegated Authority
Amendment FY 2019 dtd 2/22/2019, Delegated Authority FY 2019 dtd
2/22/2018, Delegated Authority Amendment FY 2019 dtd 8/20/2018,
Delegated Authority Amendment FY 2018 dtd 2/27/2018, Delegated
Authority FY 2018 dtd 3/17/2017, Delegated Authority FY 2022 dtd
4/14/2021, Delegated Authority FY 2021 dtd 1/16/2020, Delegated
Authority FY 2020 dtd 2/22/2019, redacted 4/20/2022 – 4/21/2022 text
messages re lethal chemical preservation, execution, execution preparation,
and lab reports for Smith, lethal drug lab results produced in response to
public records request (161 pages)

1283.

133

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1284.

5/13/2022 draft letter from Debra Inglis providing test results re
Midazolam and Potassium Chloride for Oscar Smith's execution produced
in response to public records request

1285.

5/13/2022 draft letter from Debra Inglis responding to 5/11/2022 request
for records produced in response to public records request

1286.

5/13/2022 draft letter from Debra Inglis providing records in response to
4/21/2022 request re Oscar Smith's scheduled execution produced in
response to public records request

1287.

5/13/2022 draft letter from Debra Inglis providing records in response to
4/22/2022 request re executions produced in response to public records
request

1288.

5/13/2022 letter from Debra Inglis responding to 4/25/2022 request for
records with cost produced in response to public records request

1289.

5/13/2022 draft letter from Debra Inglis responding to 4/25/2022 request
for records with cost produced in response to public records request

1290.

5/13/2022 draft letter from Debra Inglis providing records in response to
4/25/2022 request for records produced in response to public records
request

1291.

Redacted April 2021 - Feb 2022 Electric chair testing logs, redacted Feb
2022 - April 2022 Training rosters re electrocution, lethal injection,
protocol, and training materials, April 2022 lethal drug inventory log,
4/12/2022 redacted [Pharmacy] invoice, Tennessee Board of Pharmacy and
DEA license, March - April 2022 redacted emails re lethal drugs and
supplies procurement, Media selections and Info for Smith's execution,
Smith's Affidavit re defense counsel selection at execution, April 2022
emails re Smith attorney visitation, Victim services letters and emails re
attendance at Smith's execution produced in response to public records
request (428 pages)

1292.

Victim services letters re attendance at Smith's execution, Orders and
filings re Oscar Smith, Affidavit re method of execution, letter re method
of execution, last meal request, Smith's Spiritual Advisor NDA and records
produced in response to public records request (75 pages)

1293.

Redacted letters, inmate inquiries, forms and emails re religious
accommodations, visitations and attendance for Smith's execution, inmate
inquiries re disposition of Smith's belongings after death, Smith's property
and tool inventory, TDOC offender info, Microsoft outlook notification for

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visits, TDOC disciplinary records, Smith Grievance docs, Death Watch
logs, Smith clothing card, Record of Staff Visits, and USP Pharmaceutical
Compounding bulletin produced in response to public records request (122
pages)
1294.

USP Pharmaceutical Compounding bulletin, Midazolam storage and
preparation instructions, Potassium Chloride preparation instructions,
emails re Smith's reprieve, statement on Smith's temporary reprieve,
Governor's reprieve, redacted 4/20/2022 – 4/21/2022 text messages re
lethal chemical preservation, execution, execution preparation, and lab
reports for Smith, Inventory and Use for Midazolam and Potassium
Chloride, sterile compounding guidelines, 4/21/2022 emails re Zagorski's
order setting execution and reprieve produced in response to public
records request (83 pages)

1295.

Records in response to Federal Public Defender's request for records per
TPRA for Smith and lethal drug lab results produced in response to public
records request

1296.

Pharmaceutical compounding, Midazolam and Potassium Chloride
protocols, emails, Reprieve info, text messages, drug inventories, sterile
compounding docs produced in response to public records request

1297.

Memorandum re religious accommodations, letters re upcoming execution,
Inmate inquiry forms, emails, Smith's personal property logs, Tool
inventories, TDOC offense info, visitation records, TDOC Disciplinary
records, Grievance records, Death watch records, TDOC clothing card,
Record of staff visits, pharmaceutical compounding produced in response
to public records request

1298.

Letters re attendance at execution, Orders and filings, emails, Affidavit
Concerning Method of Execution, Notification letter, Last meal request,
NDA for spiritual advisor produced in response to public records request

1299.

Electric chair testing logs, training logs and materials, drug inventories and
purchase invoice, Tennessee Pharmacy license, DEA card, emails re lethal
drugs, media lottery drawing for attendance at execution records, victim
records produced in response to public records request

1300.

5/13/2022 letter from Debra Inglis enclosing records re scheduled
execution of Oscar Smith, emails re Smith's reprieve, statement on Smith's
temporary reprieve, Governor's reprieve, redacted 4/20/2022 – 4/21/2022
text messages re lethal chemical preservation, execution, execution
preparation, and lab reports for Smith, 4/21/2022 emails re Zagorski's order
setting execution and reprieve produced in response to public records
request (20 pages)

135

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1301.

5/13/2022 letter from Debra Inglis enclosing records re scheduled
execution of Oscar Smith, emails re Smith's reprieve, statement on Smith's
temporary reprieve, Governor's reprieve, 4/21/2022 emails re Zagorski's
order setting execution and reprieve, redacted Delegated Authority
Amendment FY 2019 dtd 2/22/2019, Delegated Authority FY 2019 dtd
2/22/2018, Delegated Authority Amendment FY 2019 dtd 8/20/2018,
Delegated Authority Amendment FY 2018 dtd 2/27/2018, Delegated
Authority FY 2018 dtd 3/17/2017, Delegated Authority FY 2022 dtd
4/14/2021, Delegated Authority FY 2021 dtd 1/16/2020, Delegated
Authority FY 2020 dtd 2/22/2019 produced in response to public records
request (50 pages)

1302.

5/13/2022 letter from Debra Inglis enclosing records re lethal drugs testing
results, emails re Smith's reprieve, statement on Smith's temporary
reprieve, Governor's reprieve, 4/21/2022 emails re Zagorski's order setting
execution and reprieve, 4/20/2022 – 4/21/2022 text messages re lethal
chemical preservation, execution, execution preparation, and lab reports for
Smith produced in response to public records request (20 pages)

1303.

5/13/2022 letter from Debra Inglis responding to 5/11/2022 request for
records produced in response to public records request

1304.

5/13/2022 letter from Debra Inglis enclosing records re scheduled
execution of Oscar Smith, emails re Smith's reprieve, statement on Smith's
temporary reprieve, Governor's reprieve, 4/21/2022 emails re Zagorski's
order setting execution and reprieve, 4/20/2022 – 4/21/2022 text messages
re lethal chemical preservation, execution, execution preparation, and lab
reports for Smith produced in response to public records request (20
pages)

1305.

5/13/2022 letter from Debra Inglis enclosing records re execution, redacted
Delegated Authority Amendment FY 2019 dtd 2/22/2019, Delegated
Authority FY 2019 dtd 2/22/2018, Delegated Authority Amendment FY
2019 dtd 8/20/2018, Delegated Authority Amendment FY 2018 dtd
2/27/2018, Delegated Authority FY 2018 dtd 3/17/2017, Delegated
Authority FY 2022 dtd 4/14/2021, Delegated Authority FY 2021 dtd
1/16/2020, Delegated Authority FY 2020 dtd 2/22/2019 produced in
response to public records request (44 pages)

1306.

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1307.

Notepad doc produced in response to public records request

1308.

Recs re temperature in the refrigerator storing lethal drugs from 4/13/2022
- 4/21/2022 produced in response to public records request

1309.

Notepad doc produced in response to public records request

1310.

Recs re temperature in the refrigerator storing lethal drugs from 2/25/2022
- 4/21/2022 produced in response to public records request

1311.

8/24/2018 Letter from Debra Inglis requesting that inadvertently disclosed
confidential records through the TPRA be returned pursuant to Rule 4.4(b)
of the Rules of Professional Conduct produced in response to public
records request

1312.

9/10/2018 Letter from Debra Inglis in response to 9/4/2018 Letter and
requesting return of documents within 7 days produced in response to
public records request

1313.

8/30/2018 Letter from Kelley Henry responding to 8/24/2018 Letter
indicating they are not in violation of Rule 4.4(b) and are reviewing the
request produced in response to public records request

1314.

Track02 (Purported audio files, but provided as Notepad doc that cannot
be played) produced in response to public records request

1315.

Track01 (Purported audio files, but provided as Notepad doc that cannot
be played) produced in response to public records request

1316.

1317.

8/26/2019 Letter from Debra Inglis responding to 8/22/2019 request for
records produced in response to public records request

1318.

Draft of 8/26/2019 Letter from Debra Inglis responding to 8/22/2019
request for records produced in response to public records request

137

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1319.

8/22/2019 Email from Dorinda Carter forwarding 8/22/2019 request for
records re lethal injection produced in response to public records request

1320.

Draft of 1/13/2020 Letter from Debra Inglis responding to 1/9/2020 follow
up request for records produced in response to public records request

1321.

1322.

Draft of 9/25/2019 letter from Debra Inglis providing records in response
to 8/22/2019 request produced in response to public records request

1323.

11/22/2019 Draft letter from Debra Inglis providing records in response to
11/1/2019 request produced in response to public records request

1324.

11/15/2019 Letter from Debra Inglis responding to 11/1/2019 request for
additional records produced in response to public records request

1325.

9/17/2019 Letter from Debra Inglis responding to 8/22/2019 request for
records with cost produced in response to public records request

1326.

8/22/2019 Letter requesting records re lethal injection produced in
response to public records request

1327.

Delegation Authority Amendments for Execution related services in 2019

1328.

Delegation Authority Amendments for Execution related services in 2018

1329.

Delegated Authority for Execution related services in 2022

1330.

Delegated Authority for Execution related services in 2021

1331.

Delegated Authority for Execution related services in 2020

Documents from TN AG
1.

6/8/2022 Letter from Dianna Baker Shew

Lethal Injection training documents (1162 pages)

Testing Reports (69 pages)

11/27/2017 Pharmacy Services Agreement (5 pages)

138

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5.

Execution Procedures for Lethal Injection, rev 6/25/2015 (97 pages)

Ledger pages (38 pages)

Billy Irick and Donnie Johnson Chemical prep records (8 pages)
Handwritten death watch logs for Irick, Johnson, Miller and Zagorski (315
pages)

7/20/2020 Memorandum Opinion in King v. Parker case, granting in part,
denying in part Plaintiff's motion to compel and Defendants' motion for
protective order

7/20/2020 Order in King v. Parker case, re Plaintiff's motion to compel and
Defendants' motion for protective order

10.

7/19/21 Deposition transcript of [Drug Procurer] in King v. Parker case.

11.

11/18/2019 Email, Subject: Update Lab report

12.

5/15/2019 Email, Subject: This is big! DOJ opinion on FDA

13.

7/15/2019 Email, Subject [Pharmacy] True Up

14.

8/8/2019 Email, Subject Suitability Test

15.

11/20/2019 Email, Subject see attached

16.

8/15/2019 Email, Subject Scanned from a Xerox [Pharmacy] Pharmacy.pdf

17.

7/10/2019 Email, Subject RX

18.

8/9/2019 Email, Subject results

19.

12/5/2019 Email, Subject Report

20.

5/9/2019 Email, Subject report

21.

7/24/2019 Email, Subject Report

22.

7/31/2019 Email, Subject Report

23.

5/15/2019 Email, Subject RE: This is big! DOJ Opinion on FDA

24.

5/15/2019 Email, Subject RE: This is big! DOJ Opinion on FDA

139

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25.

1/29/2019 Email, Subject RE: product

26.

1/29/2019 Email, Subject Re: product

27.

1/29/2019 Email, Subject Re: product

28.

4/29/2019 Email, Subject RE: Potency report

29.

8/8/2019 Email, Subject RE: kcl protocol

30.

7/2/2019 Email, Subject RE: kcl protocol

31.

5/9/2019 Email, Subject RE: Invoices

32.

5/9/2019 Email, Subject Re: Invoices

33.

5/9/2019 Email, Subject Re: Invoices

34.

4/3/2019 Email, Subject RE: follow up

35.

7/29/2019 Email, Subject RE: Declaration

36.

7/26/2019 Email, Subject RE: Declaration

37.

7/29/2019 Email, Subject RE: Declaration

38.

10/30/2019 Email, Subject RE: API

39.

10/30/2019 Email, Subject RE: API

40.

12/20/2019 Email, Subject Re: [EXTERNAL] New invoice

41.

12/20/2019 Email, Subject Re: [EXTERNAL] New invoice

42.

6/26/2019 Email, Subject Proposed Alternative

43.

1/29/2019 Email, Subject product

44.

4/29/2019 Email, Subject Potency report

45.

2/26/2019 Email, Subject New Invoice

46.

11/26/2019 Email, Subject Lab results

47.

8/8/2019 Email, Subject KCI

140

BU T L E R I S

48.

8/8/2019 Email, Subject kcl protocol

49.

6/26/2019 Email, Subject KCI Protocol

50.

6/26/2019 Email, Subject kcl protocol

51.

6/26/2019 Email, Subject KCI

52.

9/19/2019 Email, Subject Invoices

53.

5/9/2019 Email, Subject Invoices

54.

8/7/2019 Email, Subject Invoices

55.

6/26/2019 Email, Subject http://leucadiapharma.com/anti-capitalpunishment-statement/

56.

7/2/2019 Email, Subject Fwd: kcl protocol

57.

6/28/2019 Email, Subject Fwd: kcl protocol

58.
9/24/2019 Email, Subject Fwd: Invoices
59.

5/16/2019 Email, Subject FW: [Pharmacy]

60.

10/29/2019 Email, Subject FW: potassium

61.

5/13/2019 Email, Subject FW: Midazolam

62.

7/2/2019 Email, Subject FW: kcl protocol

63.

4/2/2019 Email, Subject follow up

64.

12/3/2019 Email, Subject FedEx Shipment 777137874130: Delivery
scheduled for tomorrow

65.

12/4/2019 Email, Subject FedEx Shipment 777137874130: Delivery
scheduled for today

66.

12/4/2019 Email, Subject FedEx Shipment 777137874130: Delivered

67.

11/26/2019 Email, Subject FedEx Shipment 777076577054: Scheduled
delivery update

141

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68.

11/25/2019 Email, Subject FedEx Shipment 777076577054: Delivery
scheduled for tomorrow

69.

11/26/2019 Email, Subject FedEx Shipment 777076577054: Delivery
scheduled for today

70.

11/25/2019 Email, Subject FedEx MPS Shipment 777076577054
Notification

71.

11/26/2019 Email, Subject FedEx MPS Shipment 777076577054
Delivered

72.

7/25/2019 Email, Subject Fed Executions

73.

8/12/2019 Email, Subject ETX-190806-0007-LabReport.pdf

74.

7/26/2019 Email, Subject Declaration

75.

12/20/2019 Email, Subject Automatic reply: New Invoice

76.

10/30/2019 Email, Subject API

77.

11/21/2019 Email, Subject Alternatives

78.

8/12/2019 Email, Subject 2019-18034.pdf

79.

12/3/2019 Email, Subject Update

80.

Text messages on [Drug Procurer] cell phone from 4/6/2017 – 6/27/2018

81.

Text messages on [Drug Procurer] cell phone from 7/3/2018 – 9/26/2018

82.

Text messages on [Drug Procurer] cell phone from 10/24/18 – 7/11/19

83.

Text messages on [Drug Procurer] cell phone from 7/31/19 – 1/6/2020

84.

Text messages on [Drug Procurer] cell phone from 1/7/2020 – 5/26/2022

85.

Declaration of Sarah B. Miller in Support of Plaintiff's Motion filed
4/13/2022 in the King v. Parker case.

86.

Affidavit of John Gardiner pursuant to 28 U.S.C. Sec 1746 dated 4/11/2022
in the King v. Parker case.

87.

Declaration of Joel Zivot, MD filed 11/21/2018 in the King v. Parker case.

142

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88.

Declaration of TDOC Employee dated 12/19/2019 in the King v. Parker
case.

89.

Sworn Statement of Debra K. Inglis dated 2/14/2022 in the King v. Parker
case.

90.

Declaration of Larry D. Sasich dated 10/2/2018 in the King v. Parker case.

91.

Declaration of RMSI Officer dated 7/30/2019 in the King v. Parker case.

92.

Declaration of RMSI Mental Health Professional dated 7/29/2019 in the
King v. Parker case.

93.

Declaration of RMSI Employee dated 12/19/2019 in the King v. Parker
case.

94.

Declaration of the President of Pharmacy Z dated 3/31/2020 in the King v.
Parker case.

95.

Declaration of Tony C. Parker dated 10/5/2021 in the King v. Parker case.

96.

Declaration of David A. Lubarsky, MD dated 9/2/2018 in the King v.
Parker case.

97.

Sworn Statement of Damon Lawrence dated 3/16/2022 in the King v.
Parker case.

98.

Sworn Statement of Debra K. Inglis dated 12/1/2021 in the King v. Parker
case.

99.

Deposition transcript of Gourang P. Patel, Pharm. D. taken on 2/11/2022 in
the King v. Parker case.

100.

Deposition transcript of Joseph Antognini, M.D. taken on 1/28/2022 in the
King v. Parker case.

101.

Deposition transcript of Feng Li, M.D., J.D., Ph.D. taken on 2/3/2022 in
the King v. Parker case.

102.

Defendants 2nd Interrogatories, Request for Production and Request for
Admission dated 9/21/2021 in the King v. Parker case. (139 pages)

103.

Mays Supplemental Responses to Interrogatories and Request for
Production dated 8/19/2020 in the King v. Parker case. (226 pages)

143

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104.

Supplemental Responses dated 3/10/22 in the King v. Parker case. (77
pages)

105.

Supplemental Responses to Request for Production dated 2/14/2022 in the
King v. Parker case. (259 pages)

106.

Defendants Supplemental Responses to Discovery dated 11/17/2021 in the
King v. Parker case. (7,802 pages)

107.

Defendants Supplemental Responses to Discovery dated 11/18/2021in the
King v. Parker case. (38 pages)

108.

Defendants' Supplemental Responses to Request for Production dated
2/22/2022 in the King v. Parker case. (257 pages)

109.

Defendants' Supplemental Responses to Request for Production dated
4/5/2022 in the King v. Parker case. (31 pages)

110.

Initial Disclosures of Defendant in the King v. Parker case. (2,189 pages)

111.

Defendants' First Supplemental Responses to Request for Production in the
King v. Parker case. (54 pages)

112.

Defendants first response to Request for Production of Documents in the
King v. Parker case. (1,292 pages)

113.

2013 - 2019 Autopsy Reports from different states of executed offenders in
the King v. Parker case. (250 pages)

114.

Defendants' Supplemental responses to Request for Production dated
12/1/2021 in the King v. Parker case. (13 pages)

115.

84 pictures of the death chambers, witness room and lethal injection tubing
in the King v. Parker case

116.

2/14/2022 Sworn Statement of Debra K. Inglis in the King v. Parker case

117.

3/16/2022 Sworn Statement of Damon Lawrence in the King v. Parker case

118.

12/1/2021 Sworn Statement of Debra K. Inglis in the King v. Parker case

119.

4/13/2022 Declaration of Sarah B. Miller in Support of Plaintiff's Motion
in the King v. Parker case

120.

11/17/2021 Expert Report of Dr. Michaela Almgren in the King v. Parker
case

144

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121.

1/14/2022 Supplemental Expert Report of Dr. Michaela Almgren in the
King v. Parker case

122.

2/4/2022 Full Deposition Transcript of Dr. Michaela Almgren in the King
v. Parker case

123.

Exhibit 1 – 1/14/2021 Notice of Subpoena for Deposition and to Produce
Documents to Dr. Almgren Deposition Transcript in the King v. Parker
case

124.

Exhibit 2 – 11/17/2021 Expert Report of Dr. Michaela Almgren to Dr.
Almgren Deposition Transcript in the King v. Parker case

125.

Exhibit 3 – 1/14/2022 Supplemental Expert Report of Dr. Michaela
Almgren to Dr. Almgren Deposition Transcript in the King v. Parker case

126.

Exhibit 4 - Lethal Injection Execution Manual, rev 7/5/2018 to Dr.
Almgren Deposition Transcript in the King v. Parker case

127.

2/4/2022 Condensed Deposition Transcript of Dr. Michaela Almgren in the
King v. Parker case

128.

11/17/2021 Expert Report of Dr. Charles David Blanke in the King v.
Parker case

129.

1/18/2022 Full Deposition Transcript of Dr. Blanke in the King v. Parker
case

130.

Exhibit 1 - 12/4/2021 Notice of Subpoena for Deposition and to Produce
Documents to Dr. Blanke’s Deposition Transcript in the King v. Parker
case

131.

Exhibit 2 – 11/17/2021 Expert Report of Dr. Charles David Blanke to Dr.
Blanke’s Deposition Transcript in the King v. Parker case

132.

Exhibit 3 – 10/2/2020 Death with Dignity: The Oregon Experience and
Future Implications PowerPoint slides to Dr. Blanke’s Deposition
Transcript in the King v. Parker case

133.

Exhibit 4 - Oregon Death with Dignity Act 2020 Data Summary to Dr.
Blanke’s Deposition Transcript in the King v. Parker case

134.

1/18/2022 Condensed Deposition Transcript of Dr. Blanke in the King v.
Parker case

145

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135.

1/18/2022 (Corrected) Full Deposition Transcript of Dr. Blanke in the King
v. Parker case

136.

Exhibit 1 – 12/14/2021 Notice of Subpoena for Deposition and to Produce
Documents to Dr. Blanke’s (Corrected) Deposition Transcript in the King
v. Parker case

137.

Exhibit 2 – 11/17/2021 Expert Report of Dr. Charles David Blanke to Dr.
Blanke’s (Corrected) Deposition Transcript in the King v. Parker case

138.

Exhibit 3 – 10/2/2020 Death with Dignity: The Oregon Experience and
Future Implications PowerPoint slides to Dr. Blanke’s (Corrected)
Deposition Transcript in the King v. Parker case

139.

Exhibit 4 - Oregon Death with Dignity Act 2020 Data Summary to Dr.
Blanke’s (Corrected) Deposition Transcript in the King v. Parker case

140.

1/18/2022 (Corrected) Condensed Deposition Transcript of Dr. Blanke in
the King v. Parker case

141.

1/14/2022 Full Deposition Transcript of Craig W. Stevens, Ph. D. in the
King v. Parker case

142.

1/14/2022 Condensed Deposition Transcript of Craig W. Stevens, Ph. D. in
the King v. Parker case

143.

11/17/2021 Expert Opinion: Inappropriate Use of Midazolam in
Tennessee's Triple-Drug Lethal Injection Protocol to Craig W. Stevens, Ph.
D. Deposition Transcript in the King v. Parker case

144.

Exhibit 1 – 12/14/2021 Notice of Subpoena for Deposition and to Produce
Documents to Craig W. Stevens, Ph. D. Deposition Transcript in the King
v. Parker case

145.

Exhibit 2 – 11/17/2021 Expert Opinion: Inappropriate Use of Midazolam
in Tennessee's Triple-Drug Lethal Injection Protocol to Craig W. Stevens,
Ph. D. Deposition Transcript in the King v. Parker case

146.

Exhibit 3 – 6/11/2018 deposition transcript of Craig W. Stevens, Ph.D. to
Craig W. Stevens, Ph. D. Deposition Transcript in the King v. Parker case

147.

Exhibit 4 - Transcript of 7/9/2018 proceedings (pages 1 - 150 only) to
Craig W. Stevens, Ph. D. Deposition Transcript in the King v. Parker case

148.

Exhibit 5 - Lethal Injection Execution Manual, rev 7/5/2018 to Craig W.
Stevens, Ph. D. Deposition Transcript in the King v. Parker case

146

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149.

Exhibit 6 - July 2021 Curriculum Vitae of Craig W. Stevens, Ph.D. to
Craig W. Stevens, Ph. D. Deposition Transcript in the King v. Parker case

150.

Exhibit 7 - American Society of Anesthesiologists Continuum of Depth of
Sedation: Definition of General Anesthesia and Levels of
Sedation/Analgesia to Craig W. Stevens, Ph. D. Deposition Transcript in
the King v. Parker case

151.

Exhibit 8 – 11/1/2019 Expert Declaration of Craig W. Stevens, PH.D. to
Craig W. Stevens, Ph. D. Deposition Transcript in the King v. Parker case

152.

Exhibit 9 - Death Be Not Proud: The pharmacology of lethal drug
executions to Craig W. Stevens, Ph. D. Deposition Transcript in the King v.
Parker case

153.

1/11/2022 Full deposition transcript of Dr. Gail Van Norman in the King v.
Parker case

154.

11/17/2021 Expert Opinion of Gail A. Van Norman, MD to transcript of
Dr. Gail Van Norman in the King v. Parker case

155.

Exhibit 1 – 12/14/2021 Notice of Subpoena for Deposition and to Produce
Documents to transcript of Dr. Gail Van Norman in the King v. Parker
case

156.

Exhibit 2 – 11/17/2021 Expert Opinion of Gail A. Van Norman, MD to
transcript of Dr. Gail Van Norman in the King v. Parker case

157.

11/10/2021 Report of Dr. James S. Williams: Efficacy and Feasibility of
Firing Squad as a Means of Execution for Dr. Williams Transcript in the
King v. Parker case

158.

1/4/2022 Full deposition transcript of Dr. James Williams in the King v.
Parker case

159.

1/4/2022 Condensed deposition transcript for Dr. James Williams
Transcript in the King v. Parker case

160.

Exhibit 1 – 12/14/2021 Notice of Subpoena for Deposition and to Produce
Documents to Dr. Williams Transcript in the King v. Parker case

161.

Exhibit 2 – 11/10/2021 Report of Dr. James S. Williams: Efficacy and
Feasibility of Firing Squad as a Means of Execution to Dr. Williams
Transcript in the King v. Parker case

147

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162.

Exhibit 3 - Gunshot Wound Review by Martin L. Fackler, MD to Dr.
Williams Transcript in the King v. Parker case

163.

Exhibit 4 - Utah Technical Manual for execution by firing squad, rev
6/10/2010 to Dr. Williams Transcript in the King v. Parker case

164.

Exhibit 5 - U.S. Army's Procedure for Military Executions to Dr. Williams
Transcript in the King v. Parker case

165.

Exhibit 6 - Diagnosis of brain death by G Bryan Young, MD to Dr.
Williams Transcript in the King v. Parker case

166.

Exhibit 7 - Advanced Trauma Life Support Student Course Manual to Dr.
Williams Transcript in the King v. Parker case

167.

Exhibit 8 - Military Police - U.S. Army Corrections System: Procedures for
Military Executions to Dr. Williams Transcript in the King v. Parker case

168.

Exhibit 9 - Thread of 7/22/2015 comments on forum to Dr. Williams
Transcript in the King v. Parker case

169.

3/10/2022 Sworn Statement of Jim Biddle for Plaintiff’s fact witnesses in
the King v. Parker case

170.

Exhibit 1 - TDOC Lethal Injection Execution Manual, rev 7/5/2018 for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

171.

Exhibit 2 - Midazolam storage and preparation instructions for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

172.

Exhibit 3 - October 2017 email thread re request for a drug storage
protocol and info for a DEA # for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

173.

Exhibit 4 - Potassium Chloride preparation instructions for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

174.

Exhibit 5 - Creation, quantity, lot # and discard date logs for Potassium
Chloride and Midazolam injections for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

175.

Exhibit 6 – 9/7/2017 email re preference for procuring Midazolam first for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

148

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176.

Exhibit 7 – 9/7/2017 email thread re availability and sources for lethal
injection drugs for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

177.

Exhibit 8 – 9/7/2017 email thread re lethal drugs availability and sources
and other options for Defendant’s fact witnesses deposition transcripts in
the King v. Parker case

178.

Exhibit 9 – 9/21/2017 email thread re request to order lethal drugs used in
3 drug protocol for 20 inmates for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

179.

Exhibit 10 – 4/6/2017 email inquiring about current inventory of
Pentobarbital for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

180.

Exhibit 11 – 4/6/2017 email inquiry regarding Pentobarbital bulk order for
compounding for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

181.

Exhibit 12- 4/6/2017 email request to purchase Pentobarbital for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

182.

Exhibit 13 – 7/20/2017 email thread re Pentobarbital update and DEA
involvement for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

183.

Exhibit 14 - Handwritten notes re importation of drugs from oversea
sources for Defendant’s fact witnesses deposition transcripts in the King v.
Parker case

184.

Exhibit 15 – 4/4/2017 email thread re inquiry to buy bulk order of
Pentobarbital for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

185.

Exhibit 16 - TDOC PowerPoint slides re efforts to procure chemicals to
compound lethal injections, death row inmates and current execution law
for Defendant’s fact witnesses deposition transcripts in the King v. Parker
case

186.

Exhibit 17 – 10/30/2019 email thread discussing importing drugs and DEA
for Defendant’s fact witnesses deposition transcripts in the King v. Parker
case

149

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187.

Exhibit 18 – 6/20/2018 email thread inquiring about purchasing
Pentobarbital for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

188.

Exhibit 19 – 5/3/2019 Memorandum Opinion for the Attorney General:
Whether the FDA has Jurisdiction over Articles Intended for Use in Lawful
Executions for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

189.

Exhibit 20 – 12/4/2017 email thread re Vecuronium requiring
reconstitution for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

190.

Exhibit 21 – 11/26/2019 email with subject Lab Results for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

191.

Exhibit 22 – 8/9/2019 email indicating house sterility report is attached for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

192.

Exhibit 23 – 8/8/2019 email indicating suitability/methodology test for
KCI that was falling out of solution is attached for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

193.

Exhibit 24 – 8/8/2019 email thread re kcl protocol for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

194.

Exhibit 25 – 7/31/2019 email re Midazolam complete report for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

195.

Exhibit 26 – 7/24/2019 email indicating potency reports for the Midazolam
and KCI are attached for Defendant’s fact witnesses deposition transcripts
in the King v. Parker case

196.

Exhibit 27 – 06/2019 – 07/2019 email thread re KCI protocol for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

197.

Exhibit 28 – 5/9/2019 email indicating lab report for Midazolam is
attached for Defendant’s fact witnesses deposition transcripts in the King v.
Parker case

198.

Exhibit 29 – 4/29/2019 email indicating potency report for Midazolam
batch is attached for Defendant’s fact witnesses deposition transcripts in
the King v. Parker case

150

BU TLE R I SNOW
199.

Exhibit 30 – 8/6/2018 email indicating the lab results for sterility testing
are attached for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

200.

Exhibit 31 – 7/12/2018 email indicating a testing report is attached re
compounds for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

201.

Exhibit 32 – 11/14/2017 email requesting info on an exam, manufacturer
and to discuss contract for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

202.

Exhibit 33 – 7/17/2018 email attaching a sample prescription for ordering a
compounded preparation for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

203.

Exhibit 34 – 12/15/2017 email providing TCA 10-7-504(h) and a case for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

204.

Exhibit 35 – 6/26/2019 email providing proposed alternatives Midazolam,
Digoxin, Morphine Sulfate and Propranolol for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

205.

Exhibit 36 – 12/20/2019 Invoice for bulk shipment of Midazolam and KCI
for Defendant’s fact witnesses deposition transcripts in the King v. Parker
case

206.

Exhibit 37 – 10/26/2017 Invoice for bulk shipment of Midazolam,
Vecuronium and KCI for Defendant’s fact witnesses deposition transcripts
in the King v. Parker case

207.

Exhibit 38 – 8/16/2018 Invoice for bulk shipment of Midazolam and
Vecuronium for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

208.

Exhibit 39 – 12/28/2017 Invoice for Midazolam, Vecuronium, Sterile
water for injection and KCI for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

209.

Exhibit 40 – 10/31/2018 Invoice for Midazolam for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

210.

Exhibit 41 – 9/2018 handwritten inventories for lethal drugs for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

151

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211.

Exhibit 42 - 2017-2018 handwritten inventories for lethal drugs for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

212.

Exhibit 43 – 2/2020 – 8/2020 handwritten inventories for lethal drugs for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

213.

Exhibit 44 – 4/14/2021 Chemical Preparation Time Sheet for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

214.

Exhibit 45 – 8/13/3020 email re training requirements for compounding
and status of KCI and Midazolam remaining for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

215.

Exhibit 46 – 11/21/2017 Pharmacy Services Agreement for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

216.

Exhibit 47 – 10/18/2017 email re lethal drugs received from suppliers for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

217.

Exhibit 48 - Picture of area where lethal drugs are stored for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

218.

Exhibit 49 - Tony May's Supplemental Response to Plaintiff's First Set of
Interrogatories signed 8/19/2020 for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

219.

Exhibit 50 - Supplement to information in response to Interrogatory 8 for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

220.

Exhibit 51 – 3/30/2021 In-Service Training Course Roster for Lethal
Injection and sample documents used on day of executions for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

221.

Exhibit 52 – 4/13/2021 dated Day of Execution checklist sample for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

222.

Exhibit 53 – 4/13/2021 In-Service Training Course Roster for Lethal
Injection for Defendant’s fact witnesses deposition transcripts in the King
v. Parker case

223.

Exhibit 54 -4/13/2021 dated Lethal Injection Chemical Administration
Record sample for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

224.

Exhibit 55 - IV Team Inventory Checklist for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

152

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225.

Exhibit 56 - Physician's Inventory Checklist for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

226.

Exhibit 57 – 8/9/2018 Day of Execution - Lethal Injection Execution
Recorder Checklist for Billy Ray Irick for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

227.

Exhibit 58 – 8/9/2018 Lethal Injection Chemical Administration Record
and Prep Sheets for Billy Ray Irick for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

228.

Exhibit 59 – 8/10/2018 Newspaper article re Billy Ray Irick's execution for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

229.

Exhibit 60 – 9/2/2018 Declaration of David A. Lubarsky, MD for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

230.

Exhibit 61 – 5/16/2019 Lethal Injection Chemical Administration Record
for Donnie Johnson for Defendant’s fact witnesses deposition transcripts in
the King v. Parker case

231.

Exhibit 62 – 5/16/2019 Chemical Prep sheets for Donnie Johnson for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

232.

Exhibit 63 – 5/16/2019 Day of Execution - Lethal Injection Execution
Recorder Checklist for Donnie Johnson for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

233.

Exhibit 64 - TDOC Administrative Policies and Procedures for Standard
Firearms Qualification Training for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

234.

Exhibit 65 – 4/14/2021 Chemical Prep Sheets for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

235.

Exhibit 66 – 5/16/2018 Sample Day of Execution check list for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

236.

Exhibit 67 – 7/17/2018 Chemical Prep sheets for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

237.

Exhibit 68 – 2/22/2017 Sample Day of Execution check list for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

153

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238.

Exhibit 69 - Subpoena to Testify at a Deposition to TDOC Designees
signed on 9/10/2021 for Defendant’s fact witnesses deposition transcripts
in the King v. Parker case

239.

Exhibit 70 - Lethal Drug Prescription Orders for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

240.

Exhibit 71 - USP Pharmaceutical Compounding - Nonsterile Preparations
chapter 795 for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

241.

Exhibit 72 - USP Pharmaceutical Compounding - Sterile Preparations
chapter 797 for Defendant’s fact witnesses deposition transcripts in the
King v. Parker case

242.

Exhibit 73 – 11/28/2017 email attaching an executed agreement and
revisions to the protocols for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

243.

Exhibit 74 - Potassium Chloride preparation instructions for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

244.

Exhibit 75 - Potassium Chloride preparation instructions for Defendant’s
fact witnesses deposition transcripts in the King v. Parker case

245.

Exhibit 76 - Sample Prescription for Defendant’s fact witnesses deposition
transcripts in the King v. Parker case

246.

Exhibit 77 - Midazolam lab report for sterility for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

247.

Exhibit 78 - Midazolam lab report for potency for Defendant’s fact
witnesses deposition transcripts in the King v. Parker case

248.

Exhibit 79 - Pharmacy Board Order for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

249.

Exhibit 81 – 5/9/2019 In-Service Training Course Roster for Spike IV Bag
and Establish IV and training material for Defendant’s fact witnesses
deposition transcripts in the King v. Parker case

250.

Exhibit 82 - Tennessee Emergency Medical Services Protocol Guidelines
for Defendant’s fact witnesses deposition transcripts in the King v. Parker
case

154

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251.

Exhibit 83 - Declaration of Tony C. Parker dated 10/5/2021 for
Defendant’s fact witnesses deposition transcripts in the King v. Parker case

252.

Exhibit 1 - Lethal Injection Execution Manual rev 7/5/2018 for [Drug
Procurer] Deposition Transcript in the King v. Parker case

253.

Exhibit 2 - Midazolam storage and preparation instructions for [Drug
Procurer] Deposition Transcript in the King v. Parker case

254.

Exhibit 3 - October 2017 email thread re request for a drug storage
protocol and info for a DEA # for [Drug Procurer] Deposition Transcript in
the King v. Parker case

255.

Exhibit 4 - Potassium Chloride preparation instructions for [Drug Procurer]
Deposition Transcript in the King v. Parker case

256.

Exhibit 5 - Creation, quantity, lot # and discard date logs for Potassium
Chloride and Midazolam injections for [Drug Procurer] Deposition
Transcript in the King v. Parker case

257.

Exhibit 6 – 9/7/2017 email re preference for procuring Midazolam first for
[Drug Procurer] Deposition Transcript in the King v. Parker case

258.

Exhibit 7 – 9/7/2017 email thread re availability and sources for lethal
injection drugs for [Drug Procurer] Deposition Transcript in the King v.
Parker case

259.

Exhibit 8 – 9/7/2017 email thread re lethal drugs availability and sources
and other options for [Drug Procurer] Deposition Transcript in the King v.
Parker case

260.

Exhibit 9 – 9/21/2017 email thread re request to order lethal drugs used in
3 drug protocol for 20 inmates for [Drug Procurer] Deposition Transcript
in the King v. Parker case

261.

Exhibit 10 – 4/6/2017 email inquiring about current inventory of
Pentobarbital for [Drug Procurer] Deposition Transcript in the King v.
Parker case

262.

Exhibit 11 – 4/6/2017 email inquiry regarding Pentobarbital bulk order for
compounding for [Drug Procurer] Deposition Transcript in the King v.
Parker case

263.

Exhibit 12 – 4/6/2017 email request to purchase Pentobarbital for [Drug
Procurer] Deposition Transcript in the King v. Parker case

155

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264.

Exhibit 13 – 7/20/2017 email thread re Pentobarbital update and DEA
involvement for [Drug Procurer] Deposition Transcript in the King v.
Parker case

265.

Exhibit 14 - Handwritten notes re importation of drugs from oversea
sources for [Drug Procurer] Deposition Transcript in the King v. Parker
case

266.

Exhibit 15 – 4/4/2017 email thread re inquiry to buy bulk order of
Pentobarbital for [Drug Procurer] Deposition Transcript in the King v.
Parker case

267.

Exhibit 16 - TDOC PowerPoint slides re efforts to procure chemicals to
compound lethal injections, death row inmates and current execution law
for [Drug Procurer] Deposition Transcript in the King v. Parker case

268.

Exhibit 17 – 10/30/2019 email thread discussing importing drugs and DEA
for [Drug Procurer] Deposition Transcript in the King v. Parker case

269.

Exhibit 18 – 6/20/2018 email thread inquiring about purchasing
Pentobarbital for [Drug Procurer] Deposition Transcript in the King v.
Parker case

270.

Exhibit 19 – 5/3/2019 Memorandum Opinion for the Attorney General:
Whether the FDA for [Drug Procurer] Deposition Transcript has
Jurisdiction over Articles Intended for Use in Lawful Executions for [Drug
Procurer] Deposition Transcript in the King v. Parker case

271.

Exhibit 20 – 12/4/2017 email thread re Vecuronium requiring
reconstitution for [Drug Procurer] Deposition Transcript in the King v.
Parker case

272.

Exhibit 21 – 11/26/2019 email with subject Lab Results for [Drug
Procurer] Deposition Transcript in the King v. Parker case

273.

Exhibit 22 – 8/9/2019 email indicating house sterility report is attached for
[Drug Procurer] Deposition Transcript in the King v. Parker case

274.

Exhibit 23 – 8/8/2019 email indicating suitability/methodology test for
KCI that was falling out of solution is attached for [Drug Procurer]
Deposition Transcript in the King v. Parker case

275.

Exhibit 24 – 8/8/2019 email thread re kcl protocol for [Drug Procurer]
Deposition Transcript in the King v. Parker case

156

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276.

Exhibit 25 – 7/31/2019 email re Midazolam complete report for [Drug
Procurer] Deposition Transcript in the King v. Parker case

277.

Exhibit 26 – 7/24/2019 email indicating potency reports for the Midazolam
and KCI are attached for [Drug Procurer] Deposition Transcript in the King
v. Parker case

278.

Exhibit 27 – 06/2019 – 07/2019 email thread re KCI protocol for [Drug
Procurer] Deposition Transcript in the King v. Parker case

279.

Exhibit 28 – 5/9/2019 email indicating lab report for Midazolam is
attached for [Drug Procurer] Deposition Transcript in the King v. Parker
case

280.

Exhibit 29 – 4/29/2019 email indicating potency report for Midazolam
batch is attached for [Drug Procurer] Deposition Transcript in the King v.
Parker case

281.

Exhibit 30 – 8/6/2018 email indicating the lab results for sterility testing
are attached for [Drug Procurer] Deposition Transcript in the King v.
Parker case

282.

Exhibit 31 – 7/12/2018 email indicating a testing report is attached re
compounds for [Drug Procurer] Deposition Transcript in the King v.
Parker case

283.

Exhibit 32 – 11/14/2017 email requesting info on an exam, manufacturer
and to discuss contract for [Drug Procurer] Deposition Transcript in the
King v. Parker case

284.

Exhibit 33 – 7/17/2018 email attaching a sample prescription for ordering a
compounded preparation for [Drug Procurer] Deposition Transcript in the
King v. Parker case

285.

Exhibit 34 – 12/15/2017 email providing TCA 10-7-504(h) and a case for
[Drug Procurer] Deposition Transcript in the King v. Parker case

286.

Exhibit 35 – 6/26/2019 email providing proposed alternatives Midazolam,
Digoxin, Morphine Sulfate and Propranolol for [Drug Procurer] Deposition
Transcript in the King v. Parker case

287.

Exhibit 36 – 12/20/2019 Invoice for bulk shipment of Midazolam and KCI
for [Drug Procurer] Deposition Transcript in the King v. Parker case

157

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288.

Exhibit 37 – 10/26/2017 Invoice for bulk shipment of Midazolam,
Vecuronium and KCI for [Drug Procurer] Deposition Transcript in the
King v. Parker case

289.

Exhibit 38 – 8/16/2018 Invoice for bulk shipment of Midazolam and
Vecuronium for [Drug Procurer] Deposition Transcript in the King v.
Parker case

290.

Exhibit 39 – 12/28/2017 Invoice for Midazolam, Vecuronium, Sterile
water for injection and KCI for [Drug Procurer] Deposition Transcript in
the King v. Parker case

291.

Exhibit 40 – 10/31/2018 Invoice for Midazolam for [Drug Procurer]
Deposition Transcript in the King v. Parker case

292.

Exhibit 41 – 9/2018 handwritten inventories for lethal drugs for [Drug
Procurer] Deposition Transcript in the King v. Parker case

293.

Exhibit 42 - 2017-2018 handwritten inventories for lethal drugs for [Drug
Procurer] Deposition Transcript in the King v. Parker case

294.

Exhibit 43 – 2/2020 – 8/2020 handwritten inventories for lethal drugs for
[Drug Procurer] Deposition Transcript in the King v. Parker case

295.

Exhibit 44 – 5/16/2019 Chemical Preparation Time Sheet for [Drug
Procurer] Deposition Transcript in the King v. Parker case

296.

Exhibit 45 – 8/13/2020 email re training requirements for compounding
and status of KCI and Midazolam remaining for [Drug Procurer]
Deposition Transcript in the King v. Parker case

297.

Exhibit 46 – 11/21/2017 Pharmacy Services Agreement for [Drug
Procurer] Deposition Transcript in the King v. Parker case

298.

Exhibit 47 – 10/18/2017 email re lethal drugs received from suppliers for
[Drug Procurer] Deposition Transcript in the King v. Parker case

299.

Exhibit 48 - Picture of area where lethal drugs are stored for [Drug
Procurer] Deposition Transcript in the King v. Parker case

300.

10/20/2021 Deposition transcript of EMT 1 in the King v. Parker case

301.

Exhibit 81 – 5/9/2019 In-Service Training Course Roster for Spike IV Bag
and Establish IV and training material for EMT 1 Deposition Transcript in
the King v. Parker case

158

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302.

Exhibit 82 - Tennessee Emergency Medical Services Protocol Guidelines
for EMT 1 Deposition Transcript in the King v. Parker case

303.

10/22/2021 Deposition transcript of EMT 2 in the King v. Parker case

304.

10/21/2021 Deposition transcript of EMT 3 in the King v. Parker case

305.

Exhibit 1 - Lethal Injection Execution Manual rev 7/5/2018 for
Executioner Deposition in the King v. Parker case

306.

Exhibit 2 - Midazolam storage and preparation instructions for Executioner
Deposition in the King v. Parker case

307.

Exhibit 4 - Potassium Chloride preparation instructions for Executioner
Deposition in the King v. Parker case

308.

Exhibit 8 – 9/7/2017 email thread re lethal drugs availability and sources
and other options for Executioner Deposition in the King v. Parker case

309.

Exhibit 43 – 2/2020 – 8/2020 handwritten inventories for lethal drugs for
Executioner Deposition in the King v. Parker case

310.

Exhibit 44 – 4/4/2021 Chemical Preparation Time Sheet for Executioner
Deposition in the King v. Parker case

311.

Exhibit 49 - Tony May's Supplemental Response to Plaintiff's First Set of
Interrogatories signed 8/19/2020 for Executioner Deposition in the King v.
Parker case

312.

Exhibit 50 - Supplement to information in response to Interrogatory 8 for
Executioner Deposition in the King v. Parker case

313.

Exhibit 51 – 3/30/2021 In-Service Training Course Roster for Lethal
Injection and sample documents used on day of executions for Executioner
Deposition in the King v. Parker case

314.

Exhibit 52 – 4/13/2021 dated Day of Execution checklist sample for
Execution Deposition in the King v. Parker case

315.

Exhibit 53 – 4/13/2021 In-Service Training Course Roster for Lethal
Injection for Executioner Deposition in the King v. Parker case

316.

Exhibit 54 – 4/13/2021 dated Lethal Injection Chemical Administration
Record sample for Executioner Deposition in the King v. Parker case

159

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317.

Exhibit 55 - IV Team Inventory Checklist for Executioner Deposition in
the King v. Parker case

318.

Exhibit 56 - Physician's Inventory Checklist for Executioner Deposition in
the King v. Parker case

319.

Exhibit 57 – 8/9/2018 Day of Execution - Lethal Injection Execution
Recorder Checklist for Billy Ray Irick for Executioner Deposition in the
King v. Parker case

320.

Exhibit 58 – 8/9/2018 Lethal Injection Chemical Administration Record
and Prep Sheets for Billy Ray Irick for Executioner Deposition in the King
v. Parker case

321.

Exhibit 59 – 8/10/2018 Newspaper article re Billy Ray Irick's execution for
Executioner Deposition in the King v. Parker case

322.

Exhibit 60 – 9/2/2018 Declaration of David A. Lubarsky, MD for
Executioner Deposition in the King v. Parker case

323.

Exhibit 61 – 5/16/2019 Lethal Injection Chemical Administration Record
for Donnie Johnson for Executioner Deposition in the King v. Parker case

324.

Exhibit 62 – 5/16/2019 Chemical Prep sheets for Donnie Johnson for
Executioner Deposition in the King v. Parker case

325.

Exhibit 63 – 5/16/2019 Day of Execution - Lethal Injection Execution
Recorder Checklist for Donnie Johnson for Executioner Deposition in the
King v. Parker case

326.

Exhibit 64 - TDOC Administrative Policies and Procedures for Standard
Firearms Qualification Training for Executioner Deposition in the King v.
Parker case

327.

10/13/2021 Deposition transcript of Debra K. Inglis in the King v. Parker
case

328.

9/24/2021 Deposition transcript of IV Team Member 1 in the King v.
Parker case

329.

9/16/2021 Deposition transcript of IV Team Member 2 in the King v.
Parker case

330.

9/22/2021 Deposition transcript of IV Team Member 3 in the King v.
Parker case

160

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331.

7/29/2021 Deposition transcript of Associate Warden Ernest Lewis in the
King v. Parker case

332.

Exhibit 1- Lethal Injection Execution Manual rev 7/5/2018 for Associate
Warden Lewis Deposition in the King v. Parker case

333.

Exhibit 2 - Midazolam storage and preparation instructions for Associate
Warden Lewis Deposition in the King v. Parker case

334.

Exhibit 4 - Potassium Chloride preparation instructions for Associate
Warden Lewis Deposition in the King v. Parker case

335.

Exhibit 7 – 9/7/2017 email thread re availability and sources for lethal
injection drugs for Associate Warden Lewis Deposition in the King v.
Parker case

336.

Exhibit 8 – 9/7/2017 email thread re lethal drugs availability and sources
and other options for Associate Warden Lewis Deposition in the King v.
Parker case

337.

Exhibit 50 - Supplement to information in response to Interrogatory 8 for
Associate Warden Lewis Deposition in the King v. Parker case

338.

Exhibit 58 – 8/9/2018 Lethal Injection Chemical Administration Record
and Prep Sheets for Billy Ray Irick for Associate Warden Lewis
Deposition in the King v. Parker case

339.

Exhibit 59 – 8/10/2018 Newspaper article re Billy Ray Irick's execution for
Associate Warden Lewis Deposition in the King v. Parker case

340.

Exhibit 60 – 9/2/2018 Declaration of David A. Lubarsky, MD for
Associate Warden Lewis Deposition in the King v. Parker case

341.

Exhibit 62 – 5/16/2019 Chemical Prep sheets for Donnie Johnson for
Associate Warden Lewis Deposition in the King v. Parker case

342.

7/27/2021 Deposition transcript of Warden Tony Mays in the King v.
Parker case

343.

Exhibit 1 - Lethal Injection Execution Manual rev 7/5/2018 for Warden
Mays Deposition in the King v. Parker case

344.

Exhibit 2 - Midazolam storage and preparation instructions for Warden
Mays Deposition in the King v. Parker case

161

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345.

Exhibit 4 - Potassium Chloride preparation instructions for Warden Mays
Deposition in the King v. Parker case

346.

Exhibit 5 - Creation, quantity, lot # and discard date logs for Potassium
Chloride and Midazolam injections for Warden Mays Deposition in the
King v. Parker case

347.

Exhibit 6 – 9/7/2017 email re preference for procuring Midazolam first for
Warden Mays Deposition in the King v. Parker case

348.

Exhibit 7 – 9/7/2017 email thread re availability and sources for lethal
injection drugs for Warden Mays Deposition in the King v. Parker case

349.

Exhibit 41 – 9/2018 handwritten inventories for lethal drugs for Warden
Mays Deposition in the King v. Parker case

350.

Exhibit 42 - 2017-2018 handwritten inventories for lethal drugs for Warden
Mays Deposition in the King v. Parker case

351.

Exhibit 43 – 2/2020 – 8/2020 handwritten inventories for lethal drugs for
Warden Mays Deposition in the King v. Parker case

352.

Exhibit 49 - Tony May's Supplemental Response to Plaintiff's First Set of
Interrogatories signed 8/19/2020 for Warden Mays Deposition in the King
v. Parker case

353.

Exhibit 50 - Supplement to information in response to Interrogatory 8 for
Warden Mays Deposition in the King v. Parker case

354.

Exhibit 53 – 4/13/2021 In-Service Training Course Roster for Lethal
Injection for Warden Mays Deposition in the King v. Parker case

355.

Exhibit 58 – 8/9/2018 Lethal Injection Chemical Administration Record
and Prep Sheets for Billy Ray Irick for Warden Mays Deposition in the
King v. Parker case

356.

Exhibit 59 – 8/10/2018 Newspaper article re Billy Ray Irick's execution for
Warden Mays Deposition in the King v. Parker case

357.

Exhibit 60 - 9/2/2018 Declaration of David A. Lubarsky, MD for Warden
Mays Deposition in the King v. Parker case

358.

Exhibit 62 – 5/16/2019 Chemical Prep sheets for Donnie Johnson for
Warden Mays Deposition in the King v. Parker case

162

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359.

Exhibit 63 – 5/16/2019 Day of Execution - Lethal Injection Execution
Recorder Checklist for Donnie Johnson for Warden Mays Deposition in the
King v. Parker case

360.

Exhibit 65 – 4/14/2021 Chemical Prep Sheets for Warden Mays Deposition
in the King v. Parker case

361.

Exhibit 66 – 5/16/2018 Sample Day of Execution check list for Warden
Mays Deposition in the King v. Parker case

362.

Exhibit 68 – 2/22/2017 Sample Day of Execution check list for Warden
Mays Deposition in the King v. Parker case

363.

9/30/201 Deposition transcript of Tony Parker in the King v. Parker case

364.

11/22/2021 Deposition transcript of Tony Parker in the King v. Parker case

365.

Exhibit 83 Declaration of Tony C. Parker dated 10/5/2021 for Tony Parker
Deposition in the King v. Parker case

366.

9/29/2021 Deposition Transcript of Tony Parker as Corporate
Representative for TDOC in the King v. Parker case

367.

7/30/2021 Deposition Transcript of [Pharmacist] in the King v. Parker case

368.

Exhibit 70 - Lethal Drug Prescription Orders for [Pharmacist] Deposition
in the King v. Parker case

369.

Exhibit 71 - USP Pharmaceutical Compounding - Nonsterile Preparations
chapter 795 for [Pharmacist] Deposition in the King v. Parker case

370.

Exhibit 72 - USP Pharmaceutical Compounding - Sterile Preparations
chapter 797 for [Pharmacist] Deposition in the King v. Parker case

371.

10/1/2021 Deposition Transcript of Pharmacy Owner in the King v. Parker
case

372.

9/17/2021 Deposition Transcript of Steven Turley as Corporate
Representative for Utah Department of Corrections in the King v. Parker
case

373.

Exhibit 1 - Amended Notice of Deposition to the Utah Department of
Corrections dated 9/10/2021 in the King v. Parker case

374.

Exhibit 2 - Picture of firing squad chair and backing in the King v. Parker
case

163

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375.

Exhibit 3 - Description of the firing squad chair and backing in the King v.
Parker case

376.

Exhibit 4 – 9/30/2003 Inter-Office memorandum re estimated cost for
upcoming execution by firing-squad in the King v. Parker case

377.

Exhibit 5 - Utah Technical Manual for execution by firing squad, rev
6/10/2010 in the King v. Parker case

378.

Exhibit 6 - Picture of execution chamber in the King v. Parker case

379.

Exhibit 7 – 1/29/2014 email thread re costs of execution methods in the
King v. Parker case

Documents from Kelley Henry
1.

Plaintiff prisoners PowerPoint in the Abu Ali Abdur'Rahman matter.

05/20/2019 Request from Kelley Henry for records re the execution of
Johnson, response to request and information advising Johnson's
Midazolam was tested for potency and sterility. The sterility passed on
5/9/19 and the potency results were 104%.

04/21/2022 Email from Kelley Henry to Debbie Inglis, et al requesting that
Inglis preserve all evidence re Oscar Smith's execution that did not go
forward.

04/21/2022 Email from Kelley Henry to Debbie Inglis, et al requesting a
response re 4.20.22 email requesting proof of testing for the lethal injection
chemicals intended to be used for Oscar Smith's 04/21/2022 execution.

04/20/2022 Email from Kelley Henry to Debbie Inglis, et al requesting
proof re testing of the lethal injection chemicals intended to be used for
Oscar Smith's 04/21/2022 execution.

Documents from David Esquivel
1.

10/3/2022 Letter to Ed Stanton, et al from David Esquivel re suggested
Lethal Injection protocol recommendations

Documents from [Former Pharmacy Owner]
1.

Directions for unpacking and storage

Revised IV protocol for Midazolam

164

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3.

Chemicals Used in Lethal Injection Edited protocol

Documents from Pharmacy
1.

[Pharmacy] Pharmacy license expiring 4/30/2022

[Pharmacy] Texas Pharmacy License expiring 4/30/2024

Sterile Compounding training document

Sterile Compounding Aseptic Technique document

[Pharmacy] Pharmacy Tennessee license expiring 7/31/2022

Formula Worksheet for Sodium Hydroxide 1% Water for injection

10.

Midazolam preparation instructions

11.

3/16/2022 Oscar Franklin Smith Prescription Order for Potassium Chloride
and Midazolam

12.

Formula Worksheet for Midazolam 50 MG/ML Injection Solution

13.

Unredacted Midazolam log of prescriptions filled between 1/1/2017 8/9/2022

14.

Redacted Midazolam log of prescriptions filled between 1/1/2017 8/9/2022

15.

5/22/2018 Midazolam suitability test

16.

Logged Formula Worksheet for Potassium Chloride 15% injection solution
concentrate injectable

17.

Potassium Chloride preparation instructions

18.

Potassium Chloride log of prescriptions filled between 1/1/2017 - 8/9/2022

19.

Potassium Chloride Inventory log between 1/1/2000 - 5/11/2022

165

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65726992.v3

20.

IV Protocol

21.

7/26/2021 Hotel Booking Invoice for [Pharmacist]

22.

9/1/2021 [Pharmacy] Invoice to TDOC

23.

Formula Worksheet for Hydrochloric Acid 1% water for injection 1%

24.

Lab Report for 5/11/2018 Midazolam Potency and Endotoxins and
5/25/2018 Sterility

25.

protocols for chemicals used in lethal injection, rev. 7/11/2016

26.

Formula Worksheet for Edetate Disodium 1% water for injection

27.

[Pharmacy] DEA License expiring 2/28/2023

28.

2/11/2020 [Pharmacy] Invoice to TDOC

29.

Midazolam inventory log between 1/1/2000 - 9/17/2021

30.

Log of Midazolam made for TDOC between 1/1/2018 - 8/13/2020

31.

Log of Potassium Chloride made for TDOC between 1/1/2018 - 8/13/2020

32.

Potassium Chloride inventory log between 1/1/2000 - 9/17/2021

33.

Potassium Chloride inventory log between 1/1/2000 - 9/17/2021

34.

5/14/2018 Lab report for container closure integrity

35.

9/17/2020 Letter from B. Braun Medical Inc. to [Pharmacy] re potential
misuse of its Potassium Chloride drug product

36.

Emails from pharmacy from 2020 - 2019 (8 pages)

37.

Emails from pharmacy from 2019 (10 pages)

38.

Emails from pharmacy from 2021 (14 pages)

39.

Emails from pharmacy from 2021 (14 pages)

40.

Emails from pharmacy from 2022 - 2021 (16 pages)

41.

Emails from pharmacy from 2019 - 2018 (22 pages)

166